Reg O definitions say that bank includes a subsidiary of the bank. So, I was thinking that I didn’t need to do anything for a subsidiary as far as Reg O compliance; but, that seems too simple. So, I wanted to ask, when a bank has a subsidiary, what should be considered as far as Reg O compliance?

Determining the directors and executive officers of the sub and see if they need to be included within your insiders list.

Thank you!