Regs and Guidance
Financial Institutions
Financial institutions are subject to additional regulatory oversight when contemplating the purchase of life insurance or the implementation of a nonqualified benefit plan. It is imperative that managers remain diligent in their monitoring of the ever-changing regulatory environment impacting these programs. The sections below provide references to pertinent regulations and guidance from applicable financial regulatory agencies, including the Federal Reserve, FDIC, NCUA, and OCC.
Federal Reserve
Banking Affiliates Act of 1982Banking Affiliates Act of 1982Federal Reserve Board: Section 23A
FDIC
Interagency Advisory on Accounting for Deferred Compensation Agreements and Bank-Owned Life InsuranceInteragency Advisory on Accounting for Deferred Compensation Agreements and Bank-Owned Life InsuranceFDIC FIL-16-2004
Managing 3rd Party RiskManaging 3rd Party RiskFIL-44-2008
Call Report Revisions - Breaking Down BOLI by ProductCall Report Revisions - Breaking Down BOLI by ProductFIL-9-2011
National Credit Union Administration (NCUA)
Funding Employee Benefit Obligations with Life InsuranceFunding Employee Benefit Obligations with Life InsuranceNCUA Opinion Letters
Benefits for Employees of Federal Credit UnionsBenefits for Employees of Federal Credit UnionsSection 701.19
Office of the Comptroller of the Currency (OCC)
Sound Incentive Compensation PoliciesSound Incentive Compensation PoliciesOCC 2010-24
Interagency Statement on the Purchase and Risk Management of Life InsuranceInteragency Statement on the Purchase and Risk Management of Life InsuranceOCC Bulletin 2004-56
Bank Purchases of Life InsuranceBank Purchases of Life InsuranceOCC Bulletin 96-51
Investment in Bank-Owned Life InsuranceInvestment in Bank-Owned Life InsuranceOCC Interpretative Letter 1030
This responds to your letter requesting an opinion regarding the Bank's creation of a "rabbi trust" for the benefit of certain Bank employees.This responds to your letter requesting an opinion regarding the Bank's creation of a "rabbi trust" for the benefit of certain Bank employees.OCC Interpretative Letter 1031
Life Insurance on a Major ShareholderLife Insurance on a Major ShareholderOCC Interpretive Letter #747