M2M Regulation O Question


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    A question we received in the chat box at the close of our March M2M meeting:

    We get push back on having our Exec Officers/Insiders complete the annual survey since the regulators a few years back pulled the annual reporting, how would you address this since while the annual reporting discontinued we must still maintain the information on our end?

    Answer: There were some Regulation O reporting requirements that were repealed a few years ago, but the annual (related interest) survey to determine all of a bank’s insiders is still a requirement under 12 CFR 215.8. There are alternatives for determining insiders of a bank’s affiliates (e.g. as part of each extension of credit the borrower would indicate whether he/she is an insider).

    Here is a link to Regulation O:

    And here is a link to the Federal Register repealing some of the reporting requirements:

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