Trust Examiner School eBook

55. Access to policies and procedures (or copy of) that have been adopted by the Board of Directors to ensure compliance with Section 3(a)(4) and Section 3(a)(5) of the Securities Exchange Act of 1934 as well as Regulation R in regards to your bank brokerage activities.

[Type Management Response Here]

56. State whether you are utilizing the bank-wide or account by account approach for purposes of the trust activities exception in Section 3(a)(4) of the Securities Exchange Act of 1934 and Regulation R. Provide documentation regarding the annual calculation of the chiefly compensated test. Documentation must show fees included in relationship compensation and accounts and fees excluded from calculation.

[Type Management Response Here]

57. A list of estates under administration longer than 36 months. Also provide a list of estates under administration longer than 18 months for which you have not filed an accounting.

[Type Management Response Here]

58. A list of all accounts and their holdings.

[Type Management Response Here]

59. A list of irrevocable life insurance trusts (ILIT’s).

[Type Management Response Here]

60. A list of accounts that hold unique assets in their individual retirement accounts (IRA) such as limited partnerships, real estate or any other unique asset. Describe your process for identifying, monitoring, and controlling prohibited transactions in these accounts. Describe the process of valuing these unique assets annually.

[Type Management Response Here]

Compliance (BSA)

61. A completed BSA/AML and/or OFAC Officer(s) biographical sketch on the person (or persons) serving in BSA/AML compliance program oversight capacities. Indicate what courses these individuals have attended relating to BSA/AML and OFAC, and when these were completed.

[Type Management Response Here]

62. A copy of management's BSA/AML risk assessment of products, services, customers, and geographic locations.