Insider Activities

Other Commissions or Fees Paid to Insiders

The payment to insiders of commissions or fees derived from services they or their related interests provide to bank customers could create a conflict of interest if they are either directly or indirectly involved in the approval of a loan or other transaction at the bank for which they are receiving the commissions or fees. Such services may include the sale of title insurance, the sale of hazard insurance relating to bank collateral, legal and/or appraisal services, etc. Insiders who receive payment of commissions or fees directly or indirectly related to a loan or other bank transaction in which they have an interest should fully disclose their interest and abstain from participating in the approval of that transaction.

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