A national bank exercising fiduciary powers shall adopt and follow written policies and procedures adequate to maintain its fiduciary activities in compliance with applicable law. Among other relevant matters, the policies and procedures should address, where appropriate, the bank's:
(a) Brokerage placement practices;
(b) Methods for ensuring that fiduciary officers and employees do not use material inside information in connection with any decision or recommendation to purchase or sell any security;
(c) Methods for preventing self-dealing and conflicts of interest;
(d) Selection and retention of legal counsel who is readily available to advise the bank and its fiduciary officers and employees on fiduciary matters; and
(e) Investment of funds held as fiduciary, including short-term investments and the treatment of fiduciary funds awaiting investment or distribution.
Notes of Decisions
Anderson v. Old Nat'l Bancorp, 675 F. Supp. 2d 701 (W.D. Ky. 2009).
“”); 12 C.F.R. § 9.5 (d). Based on the evidence submitted by ONB, the facts regarding whether and when ONB sought out legal advice appear to be as follows.”
Kohn v. Glenmede Trust Co. (N.D. Ohio 2020).
“Siewert violated Section 206(a)of the Advisers Act, that Glenmede’s Insider Trading policy complied with, among other things, the standard of care as defined by federal rules (12 CFR 9.5(b)), and that Mr. Kohn violated Section 13 of the Exchange Act of 1934.”
— 12 C.F.R. § 9.5(b) — 1 case
Kohn v. Glenmede Trust Co. (N.D. Ohio 2020).
“Siewert violated Section 206(a)of the Advisers Act, that Glenmede’s Insider Trading policy complied with, among other things, the standard of care as defined by federal rules (12 CFR 9.5(b)), and that Mr. Kohn violated Section 13 of the Exchange Act of 1934.”
Annotations are extracted automatically from the opinions in the
Syfert caselaw corpus and ranked by authority, recency, and
treatment. Dots show Syfertize treatment of the citing case itself.