Another option you might consider is a board resolution (see excerpt from Reg O below) to determine who is an executive officer. Through board resolution you could exclude all that you don’t deem executive officer (i.e. vice presidents, chairman, cashier, etc.) and declare through name and title who is an executive officer. This is something that would need to be renewed annually or sooner if there are changes in your list of executive officers. You would still need to do your related interest questionnaire to determine related interested of all insiders.
12 CFR 215.2(e)(1) states: Executive officer of a company or bank means a person who participates or has authority to participate (other than in the capacity of a director) in major policymaking functions of the company or bank, whether or not: the officer has an official title; the title designates the officer an assistant; or the officer is serving without salary or other compensation.1 The chairman of the board, the president, every vice president, the cashier, the secretary, and the treasurer of a company or bank are considered executive officers, unless the officer is excluded, by resolution of the board of directors or by the bylaws of the bank or company, from participation (other than in the capacity of a director) in major policymaking functions of the bank or company, and the officer does not actually participate therein.