Maybe they are thinking of the required annual survey?
From an article in my files:
The recordkeeping requirements include conducting an annual survey to identify all insiders of the bank itself.
With respect to insiders of affiliates, it would be best for the bank to identify such insiders through the annual survey method, but Regulation O also permits the bank to identify such insiders by requiring each borrower to indicate whether the borrower is an insider of an affiliate of the bank.
No regrets, just lessons learned.