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Answer: There were some Regulation O reporting requirements that were repealed a few years ago, but the annual (related interest) survey to determine all of a bank’s insiders is still a requirement under 12 CFR 215.8.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).