For those of you that have affiliates, how are you reviewing transactions between them for compliance with the affiliate transaction requirements under Federal Reserve Act Sections 23A and 23B (now Reg W)? Do you have any sort of centralized log of the transactions that take place between the affiliates? If not, how does the person responsible for conducting the reviews identify what transactions need to be reviewed? Also, who conducts these reviews, is it the Compliance Officer or someone else? Thanks in advance for your feedback.

I think in our shop, loan review is responsible for this type of review.

What about transactions that don't involve the purchase/sale of loans between affiliates?

We have frequent transactions with affiliates. Our accounting department keeps a detailed log, and prepares reports for the board of directors detailing transactions and compliance with the Act. The logs and reports are all reviewed by our internal auditors for accuracy. Examiners have reviewed the process and are happy with it.

We report monthly to the board affiliated transactions. We obtain the info from accounting (primarily accounts payable and the controller's office) and lending. The reports are presented to the board by the CFO. The Compliance Officer certifies each month to the board that he has reviewed the report and the transactions and has no regulatory concerns.