District Circular Letters

December 16, 1999

REGULATION O: FFIEC 004

To the Chief Executive Officer of Each Member Bank in the Twelfth Federal Reserve District

Since 1979, member banks have been subject to certain reporting and disclosure requirements set forth under the Federal Reserve Board's Regulation O. These requirements were established in Titles VIII and IX of the Financial Institutions Regulatory and Interest Rate Control Act of 1978 (FIRA), as amended by the Garn-St Germain Depository Institutions Act of 1982.

A copy of form FFIEC 004 is enclosed to assist your bank and your bank's executive officers and principal shareholders in complying with the requirements set forth in Regulation O. Please duplicate the form, which has been approved by the Federal Financial Institutions Examinations Council (FFIEC), in accordance with your needs. The form is also available on the FFIEC Internet site. You should note, however, that executive officers and principal shareholders may provide the required information on other forms, if they wish.

Executive officers and principal shareholders subject to the reporting requirements must file annual reports concerning their indebtedness, and the indebtedness of their related interests, to the correspondent banks of the member bank. These reports should be filed with the member bank's board of directors by January 31 of each year. The 2000 report covers the period January 1 to December 31, 1999.

Each member bank should notify its executive officers and principal shareholders of the reporting requirements. The persons notified should include any person who was an executive officer or principal shareholder of the member bank during the period January 1 to December 31, 1999, since all of these persons are subject to reporting requirements if they were indebted to a correspondent bank of the member bank during this period. However, persons who are no longer executive officers or principal shareholders at the time the report is to be filed are not required to file a report.

Each member bank is also required to make available to its executive officers and principal shareholders a list of the member bank's correspondent banks. A correspondent bank is defined as a bank that maintains one or more correspondent accounts for a member bank during the calendar year that, aggregated, exceed certain amounts specified in the regulation.

Form FFIEC 004, or a similar form that is filed by executive officers and principal shareholders, must be kept on file at the member bank for a period of three years. These reports are not required to be made available to the public; however, the reports will be reviewed by examiners during the course of an examination of the member bank. The reports filed by executive officers and principal shareholders should not be filed with the Federal Reserve Bank or the Office of the Comptroller of the Currency.

Additional Information

For additional information about the current form or Regulation O in general, please contact our Banking Supervision and Regulation Department, at (415) 974-2932.

FEDERAL RESERVE BANK OF SAN FRANCISCO