Have any of you seen this report during your review of Regulation O?

How do you ensure EO Compliance with Sec. 215.9 Reports by executive officers, whereas if an Executive Officer becomes indebted to any bank or banks in an aggregate amount of greater than $100,000 they are required to file this report with the bank's board within 10 days of the date of the indebtedness.

I would like to think that our EOs are independently wealthy, as we have never had an EO file one.

How do you ensure your EOs complete this form?

When I request the insiders to complete the FFIEC 004, I also include a cover page that explains what else they need to disclose (beside the correspondent accounts). And it is included in the Reg O policy that goes to the BOD, but I have not seen a report either so I am thinking like you. You might just touch base with them also, if you have the chance (like if you are a smaller bank and actually know the EOs), you should include them in your Reg O training and make sure they understand it is their responsibility and what the penalties are for non-compliance on Reg O.

Thanks Anon II - I was not logged in when I posted the original question.

I like the idea of Reg O training. Who conducts the training? Compliance personnel? Training personnel? Corporate Secretary? Reg O Officer? Or do you wear all four hats?

Thanks

I do and I am the compliance /internal control/cra officer and lucky person who has the job of spreading the joy and excitement of compliance training (if I can't talk someone else into thier specialty, but since there is never anyone who just jumps up and squeals with delight when they hear Reg O mentioned, well.....). Ever provide the "Pocket Guide for Directors" at the board meeting just for fun? Tell me there is no humor in compliance!

I did that my first BOD meeting here... I think they thought I was nuts...

And can't you just wait for them to add a new director so you can pass them out again? Heehee! At least you started them out right on the nuts part so there wouldn't be any confusion on how compliance folks are! If they only knew how serious about this stuff we are!

I too, just supplied our Board and Audit Committee members with several publications based on regulator recommendations - make sure that you don't just supply them with the "pocket guide" to Detecting Red Flags in Board Reports, but that you supply them with the 500 page full guide to Detecting Red Flags in Board Reports!!!

Forgot to log in - that last Anon was me.

As far as EO reports annually, I would suggest in addition, a form that they complete on an annual basis that indicates for all EO's to list all credit with other institutions and requires them to sign at the bottom. This way, if they list NONE, then at least you have their signature to support their report of credit. I don't think that there is really any way for you to validate the information or to validate that they have not reported something.

You can also have them sign off on a form that they have received the Reg O training and understood it - again, covering the Bank.

I survey monthly each Reg O officer and get them to certify that they have no loans from other financial institutions that exceed what they could borrow from our bank.