I need some help because I am not able to find an answer. Is there any sort of requirement that indicates a bank needs to test Regulation O on an annual basis? I am not aware of any but during a team meeting today there was a discussion about Regulation O coverage and it was brought up that there is a requirement to have independent testing on an annual basis. If there is anywhere you are able to point me for this requirement I would be grateful.

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.

Recordkeeping requirement crzy2rtrn mentioned: https://www.bankersonline.com/regulations/12-215-008

Any independent audit would be based off of your institution's risk based audit schedule. It may warrant an annual audit based upon the penalties for violations: https://www.bankersonline.com/regulations/12-215-011

I agree about risk based. We opt to do it annually even though it's a lower risk area in our assessments. However, if we run into issues, it's typically due to insider overdrafts so I'd rather not go longer than annual.

Thank you all. I was thinking the same thing that Reg O coverage should be risked based but probably performed annually given the nature of the requirements. I appreciate the feedback. Great to be able to bounce these questions off others.