Do we have any obligation to report a loan to a director of another financial institution? He has no connection to our bank.

I had this argument with our state examiners last fall. They were asking for a list of loans to executive officers and directors of other financial institutions. I told them all we tracked were loans to executive officers and directors of our defined correspondent banks. They said there was not a requirement but they liked to have that information.

We have also been criticized by examiners in the past for not identifying these relationships. We have since set up a separate code of directors and officers of other financial institutions. That way, it's there when they ask for it.

We were asked for the same information on our upcoming S&S exam with the FED.