Form FFIEC 004
January 4, 1999
Circular No. 11126

Report on Indebtedness of Executive Officers and Principal Shareholders

To the Chief Executive Officers of All Member Banks in the Second Federal Reserve District:

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

A copy of Federal Financial Institutions Examination Council ("FFIEC") form 004 is available as file 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 FFIEC, in accordance with your needs. You should note, however, that executive officers and principal shareholders may use a form other than Form 004 to report the required information, 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 1999 report covers the period January 1 to December 31, 1998.

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, 1998, 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 (although a person who is not an executive officer or principal shareholder at the time the report is required to be filed is not required to file).

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 filed with the Federal Reserve Bank or the Office of the Comptroller of the Currency.

Any questions your bank may have on this matter may be directed at this Bank to John Heinze, Examining Officer, Financial Examinations.