First National Bank would like to adopt a recordkeeping system that complies with the requirements of Regulation O. Which of the following best describes the recordkeeping system required by Regulation O?
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A. B. C. D.C
Regulation O is a Federal Reserve regulation that applies to member banks and prohibits certain types of loans and transactions between member banks and their executive officers, directors, and principal shareholders. The regulation also requires member banks to maintain records that are sufficient to demonstrate compliance with the regulation.
In particular, Regulation O requires that member banks keep records that identify all extensions of credit made to executive officers, directors, and principal shareholders, as well as any transactions between the bank and those insiders. These records must include information about the purpose of the transaction, the terms of the transaction, and any collateral that secures the transaction.
To comply with these recordkeeping requirements, member banks are required to implement a recordkeeping system that is sufficient to identify all covered transactions and to enable the bank to monitor compliance with the regulation. The specific requirements for this system are not prescribed by the regulation, but must be designed to meet the needs of the bank and its compliance program.
Of the answer choices provided, option C, "a system that surveys insiders of First National annually and requires each insider to disclose his or her related interests," is the most accurate description of the recordkeeping system required by Regulation O. This is because the regulation requires member banks to maintain records that identify covered transactions, which includes any transactions with insiders. By requiring insiders to disclose their related interests, the bank can identify any transactions that may be prohibited under Regulation O.
Option A, "a system in which the bank annually surveys all executive officers of First National and its affiliates to determine the insiders' related interests," is not accurate because it only addresses executive officers and not all covered insiders, including directors and principal shareholders. Additionally, the regulation does not require the bank to survey insiders to determine their related interests, but rather requires the bank to maintain records that identify any transactions between the bank and insiders.
Option B, "a system in which the bank asks all borrowers as loans are made whether the borrower is a related interest of an insider," is not accurate because it places the burden on borrowers to disclose whether they are related interests of insiders. While this information may be useful to the bank in identifying potential Regulation O violations, it is not a sufficient recordkeeping system on its own.
Option D, "a system that requires an annual survey of affiliate insiders," is not accurate because it only addresses insiders of affiliates, not of the member bank itself. The regulation requires member banks to maintain records of transactions between the bank and insiders, regardless of whether those insiders are affiliated with the bank or its affiliates.