What banks are eligible for Expedited Application Process? Correct Answer
- Composite 1 or 2
CRA - satisfactory
Compliance 1 or 2
WC under PCA
Not subject to any written agreement (formal or informal)
4 BSA Pillars - Part 326 Correct Answer - System of Internal Controls
Independent Testing
Designated BSA Officer
Provide Training to all employees
Section 6 of FDIC Act - New Bank Application Factors Correct Answer - 1.
Adequacy of Capital Structure - T1C not less than 8% for 7 years. Initial capital
normally $2MM excess of any preopening expenses and an adequate ALLL.
2. Convenience and Needs of community to be served.
3. Consistency of Corporate Powers with purposes of the FDI act
4. Financial History and Condition
5. Future Earnings Prospects
6. General Character of Management (#1)
7. Risk presented to DIF
Insiders per Regulation O Correct Answer - Directors
Principal Shareholders
Executive Officers
Related interest of above
- company controlled by insider, or political campiagn controlled by, or for the
benefit of, the insider
Unimpaired Capital & Surplus Correct Answer - Tier 1 Capital
Tier 2 capital
, Excess ALLL
Executive Officers per Regulation O Correct Answer - Chairmen of the
Board
President
Secretary
Treasurer
Cashier
VPs
Unless specifically excluded by Board Resolution and nonparticipatory in
policy making functions
Executive Officer and Director Overdrafts Correct Answer - May not pay
overdraft for XO or director (or of bank affiliates) unless:
Written, preauthorized, interest bearing extension of credit plan that specifies
method of repayment
Written, preauthorized, transfer of funds from another account
Exception: inadvertent overdfraft of aggregate $1M or less provided not more
than 5 business days, same fee charged as any other customer.
Doesn't apply to related interests, or shareholders
SARs must be filed when? Correct Answer - Insider abuse in any amount
$5M or more when suspect known (30 days)
$25M or more when suspect unkown (60 days)
$5M when money suspect money laundering/BSA violations
Low Quality Assets - 23A Correct Answer - Adversely Classified or SM
Non-accrual
>30 days PD
TDR
Partial Payments on Retail Credit - How accounted for? Correct Answer -
90% of contractual payment considered full payments