Bank Compliance Center

In today’s banking environment as soon as one big new regulation is implemented another pops up. ICBA’s compliance training opportunities and exceptional resources, online and offline, will help your community bank stay informed and one step ahead of the regulators.

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Compliance Question of the Week

Question: Under Regulation O, are there exceptions to the general aggregate limit for insiders?

ANSWER: 

The general aggregate limits do not apply to the following:

  • Extensions of credit secured by a perfected security interest in bonds, notes, certificates of indebtedness, or Treasury bills of the United States or in other such obligations fully guaranteed as to principal and interest by the United States;
  • Extensions of credit to or secured by unconditional takeout commitments or guarantees of any department, agency, bureau, board, commission or establishment of the United States or any corporation wholly owned directly or indirectly by the United States;
  • Extensions of credit secured by a perfected security interest in a segregated deposit account in the lending bank; or Extensions of credit arising from the discount of negotiable or nonnegotiable installment consumer paper that is acquired from an insider and carries a full or partial recourse endorsement or guarantee by the insider, provided that:
  • The financial condition of each maker of such consumer paper is reasonably documented in the bank's files or known to its officers;
  • An officer of the bank designated for that purpose by the board of directors of the bank certifies in writing that the bank is relying primarily upon the responsibility of each maker for payment of the obligation and not upon any endorsement or guarantee by the insider; and
  • The maker of the instrument is not an insider.
  • The exceptions in paragraphs (d)(3)(i)(A) through (d)(3)(i)(C) of this section apply only to the amounts of such extensions of credit that are secured in the manner described therein.

Reference: 12 CFR 215.4(d)(3).

 
 

 

 


 

Compliance Vault


The ICBA Compliance Vault is now available as a member benefit to all ICBA members.

The Compliance Vault is a reliable search tool that helps you find answers to your regulatory compliance questions, with access to over 2,500 Q&As, select online courses, and documents.

Learn more & open the vault

Compliance Resources


Subscription

Bank Compliance Check Up

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Regular monitoring is essential to a successful compliance program. With the Bank Compliance Check Up Program, compliance monitoring has never been so stress-free. The program places the regulatory requirements into checklists, using a Yes, No, N/A format to allow for easy assessment of how the bank is meeting compliance requirements.

Select the desired checklist, answer the questions, add comments as applicable, and save or print the report. Use the report to demonstrate to your board of directors, management, and examiners, the effectiveness of your compliance management system.

Training agendas and quizzes are provided in over 40 compliance areas that correspond with the checklists. When a checklist is complete, review the areas of noncompliance or where there is a weakness and use the training agendas and quizzes to assist in training staff to become more compliance.

Use Bank Compliance Check Up to:

  • Determine how well your compliance program is meeting requirements.

  • Determine the effectiveness of training.

  • Evaluate the strengths of your compliance program.

  • Save time in creating reports for your board and management.

  • Train staff in areas on noncompliance.

The Bank Compliance Check Up Program uses Microsoft Excel. There are over 100 checklists available and new checklists are added as regulations and guidance change.

Your subscription includes access to the program and any updates for one year from the date of purchase.

Subscribe to Check Your Ad, Compliance Deskbook and Bulletin Service, and Bank Compliance Check Up and save $300. Purchase two of these products and save $100. New subscriptions only. Offer valid for first year of subscription only.

Must call ICBA Education to place your order and receive the discount. 800-422-7285

Initial Price
ICBA Member: $499
Nonmember: $799

Annual Digital Renewal
ICBA Member: $349
Nonmember: $649

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