I'm helping our Trust Department do some research on Regulation R. During our most recent Trust exam, the Trust Dept. was urged to review provisions of the reg and develop a policy intended to ensure compliance. We are to identify each exemption or exception available to the bank and/or trust department that would exempt the bank from registration as a broker/dealer.

Has anyone out there formulated a policy? Would you be willing to share what goes into your policy or the policy itself? I'm not very familiar with this reg, but I'm trying to provide them some ideas of where to begin.

Thanks so much.