Insider Activities
Introduction
Risks Associated with Insider Activities
Reputation Risk
Credit Risk
Liquidity Risk
Compliance Risk
Duties of the Board and Management
Policies
Duty of Care and Duty of Loyalty
Holding Companies and Other Affiliates
Compliance with Insider Laws and Regulations
12 CFR 215 — Regulation O
12 USC 375
12 USC 375a
12 USC 375b
12 USC 376
12 USC 1972(2)
Internal Controls and Audit
Compensation and Benefits Paid to Insiders
Management and Other Fees
Audit Committee Member Fees
Credit Life/Accident and Health Insurance Fees
Other Commissions or Fees Paid to Insiders
Dividends
Management Information Systems and Financial Reporting
OCC Evaluation of Insider Activities
Procedures
Quantity of Risk
Quality of Risk Management
Processes
Personnel
Control Systems
Conclusion Procedures
Appendix A: Appendix A
Appendix B: Appendix B
Regulation O Reporting Requirements
Definitions
Summary of Requirements
215.8 Records of Member Banks
215.9 Reports by Executive Officers
215.10 Reports on Credit to Executive Officers
215.11 Disclosure of Credit From Member Banks to Executive Officers and Principal Shareholders
215.12 Reporting Requirement for Credit Secured by Certain Bank Stock
215.22 Reports by Executive Officers and Principal Shareholders or their Related Interests
215.23 Disclosure of Credit from Correspondent Banks to Executive Officers and Principal Shareholders
Appendix C: Appendix C
Other Insider Laws and Regulations
12 USC 376 — Rate of Interest Paid to Insiders
12 USC 1817(k) — Reports and Disclosure by Banks of Extensions of Credit to Executive Officers or Principal Shareholders or Their Related Interests
12 USC 1818 — Enforcement Authority Against Institution-Affiliated Parties
12 USC 1831i and 12 CFR 5.51 — Proposed Changes in Directors and Senior Executive Officers
12 USC 1972 — Certain Tying Arrangements Prohibited; Correspondent Accounts
12 USC 3202 through 3203 and 12 CFR 26 — Management Interlocks
12 CFR 2 — Disposition of Credit Life Insurance Income
12 CFR 31 — Extensions of Credit to National Bank Insiders
Appendix D: Appendix D
Acceptance of Items of Value
Appendix E: Appendix E
Report of Indebtedness (FFIEC Form 004)
References
Insider Activities
Introduction
Insider Activities
Introduction