Insider Activities

Dividends

The board of directors should ensure that any proposed dividend is consistent with the bank’s capital and strategic plans and will not have an adverse impact on capital adequacy. The dividend policies of a national bank should be consistent with its capacity to pay and should not be based in any way on the needs of insiders or shareholders. Dividend policies based solely on insiders’ or their interests’ need for income are considered unsafe and unsound. If a dividend in excess of the limit imposed by 12 USC 60(b) is contemplated, the bank should request permission from the OCC, in advance, to pay the dividend.

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