The bank should have procedures to ensure that:
Annual financial statements are provided or made available to each person who ordinarily would receive a regular accounting with respect to each participating account.
CIFs are properly reported in Call Report Schedule RC-T.
A1 funds (and other types of funds using the 3(c)(3) exemption in the ’40 Act) are not advertised, except in connection with ordinary advertising of the fiduciary services of the bank, and A2 funds do not advertise predictions of the fund’s performance (and comply with other restrictions on advertising).
Fund records are retained for three years from the later of the termination of the fund or the termination of litigation relating to the fund.
Fund records are maintained separate and distinct from other nonfiduciary records of the bank.