Review the insider policies for procedures governing:

• Disclosure to the board of actual or potential conflicts of interest.

• Abstention by insiders from the approval process on any transaction in which the insider may benefit directly or indirectly from the decision.

• Officers who may enter into insider transactions on the bank’s behalf.

Determine whether the policies appropriately address disclosures by insiders:

• Of any interest in the business of a borrower or other bank customer.

• Of any interest in the companies who are supplying goods or services to the bank or doing business on behalf of the bank.

• Of transactions with the bank including payment to or receipt from the bank of fees or commissions.

• Of other related interests as required in 12 CFR 215.

Determine whether the policies clearly communicate the circumstances and conditions under which:

• The bank may enter into transactions with insiders or their related interests.

• The bank will make the use of its facilities, real or personal property, or personnel available to insiders.

Assess whether the policies adequately address prohibitions that preclude insiders from:

• Soliciting anything of value from anyone in return for any business service or confidential information of the bank.

• Accepting anything of value other than their bona fide salary, wages, fees, or other compensation paid in the usual course of business by their employer, from anyone in connection with the business of the bank, either before or after a transaction is discussed or consummated.

• Accepting gifts, bequests, or other items of value from bank customers or other persons with business dealings with the bank.

• Using insider information in securities transactions.

Review policy requirements for arm’s length transactions:

• With insiders or their related interests.

• With businesses with which the bank deals if the business is one in which an insider has an interest.

Determine whether the policies adequately address the consequences of breaches of fiduciary duty, unethical conduct, violations of law, or suspected criminal activity, and contain effective internal reporting mechanisms as well as SAR filing processes.

Review policy requirements for documentation of insider transactions.

Determine whether the bank periodically reviews its insider policies to ensure that they reflect any changes in laws or regulations. Determine whether:

• Insiders have copies of the document and have signed an acknowledgement form.

• Insiders are advised of their responsibilities.

• The bank provides training updates.