Model BSA Information-Sharing Agreements Between States, Federal Regulators, FinCEN & the IRS

Nationwide Cooperative Agreement
In 1997, state banking departments and the federal banking agencies signed agreements to create a streamlined regulatory system for state-chartered banks that operate across state lines. The Nationwide Cooperative Agreement and Nationwide State-Federal Agreement have been signed by every state banking department in the country.

Nationwide State-Federal Supervisory Agreement

November 14, 1996

State Foreign Bank Office (FBO) Agreement

In 1998, state banking departments responsible for foreign bank supervision signed two agreements with each other and with the federal banking agencies to develop a coordinated supervisory program for U.S. offices of foreign banks. The State FBO Agreement and State-Federal FBO Agreement provide foreign banks operating in more than one state with the same supervisory efficiencies available to domestic state-chartered banks.

State-Federal Foreign Bank Office (FBO) Agreement

November 20, 1998: State banking departments responsible for foreign bank supervision signed two agreements with each other and with the federal banking agencies to develop a coordinated supervisory program for U.S. offices of foreign banks. The State FBO Agreement and State-Federal FBO Agreement provide foreign banks operating in more than one state with the same supervisory efficiencies available to domestic state-chartered banks.

Nationwide Cooperative Agreement Multi-State Trust Institutions

Drafted in 1999: State Banking Departments are committed to making the state charter an effective and efficient option for the delivery of interstate trust services. The purposes of the Nationwide Cooperative Agreement for the Supervision and Examination of Multistate Trust Institutions (Nationwide Trust Agreement) are to: promote a comprehensive nationwide system to supervise and examine multi-state trust institutions cooperatively among the states; to foster effective coordination and communication among the parties to the Agreement; to avoid unnecessary regulatory duplication and to facilitate the process of supervision and examination with the least regulatory burden to multi-state trust institutions.

To date, 42 State Banking Departments have executed the Nationwide Trust Agreement because state bank regulators recognize that the trust business is by nature an interstate business that demands an enlightened, coordinated supervisory approach among state banking agencies. Although the remaining states have indicated that statutory restrictions prevent them from executing the agreement, CSBS is working with those departments to identify alternative ways to enhance a the coordinated system of trust supervision that the Nationwide Trust Agreement is intended to provide.
 

In 1999, state bank supervisors approved a nationwide agreement to create a home-state supervisory structure for multi-state trust operations. Click here to view the states that have signed the agreement.

Model Cooperative Agreement with the NAIC

Model Information Sharing Agreement between State Bank Commissioners and State Insurance Commissioners.

Years before Gramm-Leach-Bliley allowed for greater affiliation between banks and insurance companies, regulators representing the Conference of State Bank Supervisors (CSBS) and the National Association of Insurance Commissioners (NAIC) developed the Model Information Sharing Agreement to improve communication between state insurance commissioners and state bank supervisors. The agreement functions primarily as a tool for state bank and insurance supervisors to communicate and coordinate the regulation of banks engaged in insurance sales.

Such Agreements help both banking and insurance supervisors avoid imposing regulatory burden, such as making redundant requests for information or failing to coordinate should it became necessary to address a consumer complaint. Coordination in these areas also benefits banks engaged in insurance sales and leads to more efficient, streamlined supervision.

Model Multi-State Trust Institutions Act

CSBS Statutory Options for Multi-State Trust Activities.
 

Click here to view the States that have incorporated elements of the CSBS Multistate Statutory Options into their trust statutes

State/Federal Supervisory Protocol

The overall purpose of this Protocol is to outline a basic framework for supervising state-chartered banks with interstate branches.