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An expertly-staffed hotline, federal regulatory tools, policies and procedures, and unlimited reviews for small-to-medium community banks across the U.S. — the only all-inclusive banking compliance advisory. C/A’s nearly 1700 products and tools support 48 separate bank compliance areas –an unlimited-access Bank Compliance Library – conforms to the most recently published federal banking rules and regulations. Whether you are building institutional exam-readiness or a bank compliance program, C/A has all the resources, access, and availability for one membership subscription. Co-owned by the Virginia Bankers Association and 28 other state bankers associations across the country. Contact C/A’s Membership Development Team at (888) 353-3933 or at: info@compliancealliance.com. To learn more about C/A’s new Virtual Compliance Officer service or call (833) 683-0701.

Compliance Alliance Featured Q&A

Question:

For Regulation O purposes, does our Board of Directors have to submit annual personal financial statements?

Answer:

Strictly speaking, there is not an explicit requirement under Regulation O to have any insiders – or the board – within scope submit an annual personal financial statement; such a decision is generally going to be more of a safety and soundness consideration, and a determination that is reliant upon on the bank’s own internal / investor guidelines. But – acknowledging that the spirit and intention of Regulation O is to prevent the preferential treatment of a bank’s insiders – it is important to keep in mind that if the bank requires annual personal financial statements from other “non-insider” borrowers on similar credit transactions, then that same requirement should likely be imposed equally to any insider within scope.

If ever in doubt, Compliance Hub’s Regulation O Toolkit is packed with resources that can help your bank navigate the requirements and best practices as they relate to extensions of credits to insiders. 

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