||Reporting of Officers' Borrowings at Other Banks
Section 211(2) of the Banking Code of 1969 requires:
Each bank officer shall make a written report to the
directors, at the time of the annual meeting of the bank directors,
as to all of his outstanding indebtedness to any bank or national
banking association which report shall state the dates of all
loans, the current balances thereof and whether or not such
indebtedness is secured.
The above-quoted section of the Banking Code requires every officer
to make a written report to the directors of the bank in which
he is employed regarding all outstanding indebtedness to banks.
While the statute does not specifically require a written report
from each officer when no indebtedness is outstanding, it is apparent
that the intent of the act is that the Board of Directors shall
be aware of all outstanding indebtedness. It has become apparent
through examination procedures that occasionally all outstanding
indebtedness is not being reported either through negligence,
willful intentions, or because an officer is unaware of his obligation
to report such outstanding indebtedness.
To prevent negligence or inadvertent failure to report outstanding
indebtedness, the position of this Bureau is that a written
report should be required from each officer indicating all outstanding
indebtedness to banks or national banking associations, or that
there is no outstanding indebtedness of the officer to any bank
or national banking association.
||Robert P. Briggs, Commissioner
||June 15, 1972