Common use of CONFLICT OF INTEREST POLICY Clause in Contracts

CONFLICT OF INTEREST POLICY. (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written, comprehensive conflict of interest policy applicable to the Bank’s directors, executive officers, and employees (collectively, “Insiders”) and related interests of such Insiders. The policy, in addition to defining a conflict of interest, shall address: (a) avoidance of conflicts of interest and breaches of fiduciary duty, and the appearance of conflicts of interest; (b) involvement in the loan approval process of Insiders who may benefit directly or indirectly from the decision to grant credit; (c) disclosure of actual and potential conflicts of interest to the Board, and periodic disclosure of “related interests” as defined by 12 C.F.R. Part 215; (d) requirements for arms-length dealing in any transactions by Insiders, or their related interests, involving the Bank’s sale, purchase, or rental of property and services; (e) disclosure of any Insider’s material interest in the business of a borrower, a loan applicant, or other customer of the Bank; and (f) restrictions on and disclosure of receipt of anything of value by Insiders, directly or indirectly, from borrowers, loan applicants, other customers, or suppliers of the Bank. (2) Upon adoption, a copy of this conflict of interest policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) Within sixty (60) days, the Board shall conduct a review of the Bank’s existing relationships with its directors, executive officers, employees and their related interests for the purpose of identifying relationships not in conformity with the policy. The Board shall ensure that: (a) any nonconforming relationships are brought into conformity with the policy within sixty (60) days; and (b) that within sixty (60) days the Bank is properly reimbursed for: (i) any excess or improper payments to Insiders and their related interests; and (ii) any excess or improper payments for services provided by Insiders and their related interests. (4) Thereafter, the Board shall review all proposed transactions, or modifications of existing relationships, between the Bank and any of its directors, executive officers, employees, and their related interests. Documentation supporting these reviews shall be in writing and preserved in the Bank.

CONFLICT OF INTEREST POLICY. (1) Within sixty forty-five (6045) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written, comprehensive conflict of interest policy applicable to the Bank’s 's directors, principal shareholders, executive officers, affiliates, and employees (collectively, “Insiders”) and related interests of such Insiders. The policy, in addition to defining a conflict of interest, shall address: (a) avoidance of conflicts of interest and breaches of fiduciary duty, and the appearance of conflicts of interest; (b) involvement in the loan approval process of Insiders who may benefit directly or indirectly from the decision to grant credit; (c) disclosure of actual and potential conflicts of interest to the Board, and periodic disclosure of “"related interests” " as defined by 12 C.F.R. Part 215; (d) requirements for arms-length dealing in any transactions by Insiders, or their related interestsorganizations, involving the Bank’s 's sale, purchase, or rental of property and services; (e) disclosure of any Insider’s 's material interest in the business of a borrower, a loan an applicant, or other customer of the Bank; and (f) restrictions on and disclosure of receipt of anything of value by Insiders, directly or indirectly, from borrowers, loan applicants, other customers, or suppliers of the Bank. (2) Upon adoption, a copy of this conflict of interest policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article. (4) Within sixty forty-five (6045) days, the Board Compliance Committee shall conduct a review of the Bank’s 's existing relationships with its directors, executive officers, affiliates, principal shareholders, employees and their related interests for the purpose of identifying relationships not in conformity with the policy. The Board shall ensure that: (a) any nonconforming relationships are brought into conformity with the policy within sixty forty-five (6045) days; and (b) that within sixty forty-five (6045) days the Bank is properly reimbursed for: (i) any excess or improper payments to Insiders and their related interests; and (ii) any excess or improper payments for services provided by Insiders and their related interests. (4) . Thereafter, the Board shall review all proposed transactions, or modifications of existing relationships, between the Bank and any of its directors, executive officers, employeesaffiliates, principal shareholders, employees and their related interests. Documentation supporting these reviews shall be in writing and preserved in the Bank.

CONFLICT OF INTEREST POLICY. (1) Within sixty ninety (6090) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written, comprehensive conflict of interest policy applicable to the Bank’s and the Bank’s holding company’s directors, principal shareholders, executive officers, affiliates, and employees (collectively, “Insiders”) and related interests of such Insiders. The policy, in addition to defining a conflict of interest, shall address: (a) avoidance of conflicts of interest and breaches of fiduciary duty, and the appearance of conflicts of interest; (b) involvement in the loan approval process of Insiders who may benefit directly or indirectly from the decision to grant credit; (c) disclosure of actual and potential conflicts of interest to the Board, and periodic disclosure of “"related interests” " as defined by 12 C.F.R. Part 215; (d) requirements for arms-length dealing in any transactions by Insiders, or their related interestsorganizations, involving the Bank’s 's sale, purchase, or rental of property and services; (e) disclosure of any Insider’s material interest in the business of a borrower, a loan an applicant, or other customer of the Bank; and (f) restrictions on and disclosure of receipt of anything of value by Insiders, directly or indirectly, from borrowers, loan applicants, other customers, or suppliers of the Bank. (2) Upon adoption, a copy of this conflict of interest policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article. (4) Within sixty ninety (6090) days, the Board Compliance Committee shall conduct a review of all Insider transactions over $5,000 per transaction or contract entered into within the Bank’s existing relationships with its directors, executive officers, employees and their related interests past thirty six (36) months from the date of this Agreement for the purpose of identifying relationships transactions not in conformity with the policy. The Board shall ensure that: (a) any nonconforming relationships are brought into conformity with the policy within sixty (60) daysdays of the completion the review; and (b) that within sixty (60) days of the completion of the review the Bank is properly reimbursed for: (i) any excess or improper payments to Insiders and their related interests; and (ii) any excess or improper payments for services provided by Insiders and their related interests. (4) Thereafter, the Board shall review all proposed transactions, or modifications of existing relationships, between the Bank and any of its directors, executive officers, employees, and their related interests. Documentation supporting these reviews shall be in writing and preserved in the Bank.

CONFLICT OF INTEREST POLICY. (1) Within sixty ninety (6090) days, the Board shall review the Bank's consulting agreement and relationship with Network Health Financial Services to determine whether there are any actual or potential conflicts of interest resulting therefrom and shall seek to eliminate or control any such conflicts by amending the agreement or through other appropriate means. (2) Within ninety (90) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written, comprehensive conflict of interest policy applicable to the Bank’s 's and the Bank's holding company's directors, principal shareholders, executive officers, affiliates, employees and employees consultants (collectivelyInsiders), “Insiders”) and the related interests of such Insiders. The policy, in addition to defining a conflict of interest, shall address: (a) avoidance of conflicts of interest and breaches of fiduciary duty, and the appearance of conflicts of interest; (b) involvement in the loan approval process of Insiders who may benefit directly or indirectly from the decision to grant credit; (c) disclosure of actual and potential conflicts of interest to the Board, and periodic disclosure of “"related interests” " as defined by 12 C.F.R. Part 215; (d) requirements for arms-length dealing in any transactions by Insiders, or their related interests, involving the Bank’s sale, purchase, or rental of property and services; (e) disclosure of any Insider’s 's material interest in the business of a borrower, a loan an applicant, or other customer of the Bank; and (fe) restrictions on and disclosure of receipt of anything of value by Insiders, directly or indirectly, from borrowers, loan applicants, other customers, or suppliers of the Bank. (23) Upon adoption, a copy of this conflict of interest policy shall be forwarded to the Assistant Deputy Comptroller for reviewreview and approval. (34) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article. (5) Within sixty ninety (6090) days, the Board Compliance Committee shall conduct a review of the Bank’s 's existing relationships with its and its holding company's directors, executive officers, employees affiliates, principal shareholders, employees, consultants and their related interests for the purpose of identifying relationships not in conformity with the policy. The Board shall ensure that: (a) any nonconforming relationships are brought into conformity with the policy within sixty ninety (6090) days; and (b) that within sixty ninety (6090) days the Bank is properly reimbursed for: (i) any excess or improper payments to Insiders and their related interests; and (ii) any excess or improper payments for services provided by Insiders and their related interests. (4) Thereafter, the Board shall review all proposed transactions, or modifications of existing relationships, between the Bank and any of its directors, executive officers, employees, and their related interests. Documentation supporting these reviews shall be in writing and preserved in the Bank.

CONFLICT OF INTEREST POLICY. (1) Within sixty thirty (6030) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written, comprehensive conflict of interest policy applicable to the Bank’s directors, principal shareholders, executive officers, affiliates, and employees (collectively, “Insiders”) and related interests of such Insiders. The policy, in addition to defining a conflict of interest, shall address: (a) avoidance of conflicts of interest and breaches of fiduciary duty, and the appearance of conflicts of interest; (b) involvement in the loan approval process of Insiders who may benefit directly or indirectly from the decision to grant credit; (c) disclosure of actual and potential conflicts of interest to the Board, and periodic disclosure of “"related interests” " as defined by 12 C.F.R. Part 215; (d) requirements for arms-length dealing in any transactions by Insiders, or their related interestsorganizations, involving the Bank’s 's sale, purchase, or rental of property and services; (e) disclosure of any Insider’s material interest in the business of a borrower, a loan an applicant, or other customer of the Bank; and (f) restrictions on and disclosure of receipt of anything of value by Insiders, directly or indirectly, from borrowers, loan applicants, other customers, or suppliers of the Bank. (2) Upon adoption, a copy of this conflict of interest policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article. (4) Within sixty (60) days, the Board Compliance Committee shall appoint a qualified, independent certified public accounting firm to conduct a review of the Bank’s 's existing relationships with its directors, executive officers, employees Insiders and their related interests interests, for the purpose of identifying relationships not in conformity with the policy, and to conduct a review of other lending relationships detailed in the most recent OCC Report of Examination. (5) Prior to appointing any firm to conduct this review, the Board shall submit to the Assistant Deputy Comptroller sufficient information to evaluate the qualifications, experience and background of the firm, as well as a proposed engagement letter setting forth the scope of the review. (6) The Assistant Deputy Comptroller shall have the power to disapprove the appointment of the proposed firm. However, the lack of disapproval of such firm shall not constitute an approval or endorsement of the firm. (7) The review required by paragraph (4) of this Article shall be completed and a written report shall be submitted to the Board within one hundred and twenty (120) days. Within thirty (30) days of reviewing the auditor’s report, the Board shall ensure that: (a) any nonconforming relationships are brought into conformity with the policy within sixty (60) dayspolicy; and (b) that within sixty (60) days the Bank is properly reimbursed for: (i) any excess or improper payments to Insiders and their related interests; and (ii) any excess other amounts due to the Bank as a result of conduct identified in the Report of Examination or improper payments for services provided by Insiders and their related intereststhe auditor’s report. (4) 8) Thereafter, the Board shall review all proposed transactions, or modifications of existing relationships, between the Bank and any of its directors, executive officers, employees, Insiders and their related interests. Documentation supporting these reviews shall be in writing and preserved in the Bank.

CONFLICT OF INTEREST POLICY. (1) Within sixty ninety (6090) days, the Board shall review the Bank’s consulting agreement and relationship with Network Health Financial Services to determine whether there are any actual or potential conflicts of interest resulting therefrom and shall seek to eliminate or control any such conflicts by amending the agreement or through other appropriate means. (2) Within ninety (90) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written, comprehensive conflict of interest policy applicable to the Bank’s and the Bank’s holding company’s directors, principal shareholders, executive officers, affiliates, employees and employees consultants (collectivelyInsiders), “Insiders”) and the related interests of such Insiders. The policy, in addition to defining a conflict of interest, shall address: (a) avoidance of conflicts of interest and breaches of fiduciary duty, and the appearance of conflicts of interest; (b) involvement in the loan approval process of Insiders who may benefit directly or indirectly from the decision to grant credit; (c) disclosure of actual and potential conflicts of interest to the Board, and periodic disclosure of “related interests” as defined by 12 C.F.R. Part 215; (d) requirements for arms-length dealing in any transactions by Insiders, or their related interests, involving the Bank’s sale, purchase, or rental of property and services; (e) disclosure of any Insider’s material interest in the business of a borrower, a loan an applicant, or other customer of the Bank; and (fe) restrictions on and disclosure of receipt of anything of value by Insiders, directly or indirectly, from borrowers, loan applicants, other customers, or suppliers of the Bank. (23) Upon adoption, a copy of this conflict of interest policy shall be forwarded to the Assistant Deputy Comptroller for reviewreview and approval. (34) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article. (5) Within sixty ninety (6090) days, the Board Compliance Committee shall conduct a review of the Bank’s 's existing relationships with its and its holding company’s directors, executive officers, employees affiliates, principal shareholders, employees, consultants and their related interests for the purpose of identifying relationships not in conformity with the policy. The Board shall ensure that: (a) any nonconforming relationships are brought into conformity with the policy within sixty ninety (6090) days; and (b) that within sixty ninety (6090) days the Bank is properly reimbursed for: (i) any excess or improper payments to Insiders and their related interests; and (ii) any excess or improper payments for services provided by Insiders and their related interests. (46) Thereafter, the Board shall review all proposed transactions, or modifications of existing relationships, between the Bank and any of its or its holding company’s directors, executive officers, affiliates, principal shareholders, employees, consultants and their related interests. Documentation supporting these reviews shall be in writing and preserved in the Bank.

CONFLICT OF INTEREST POLICY. (1) Within thirty (30) sixty (60) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written, comprehensive conflict of interest policy applicable to the Bank’s and the Bank’s holding company’s directors, principal shareholders, executive officers, affiliates, and employees (collectively, “Insiders”) and related interests of such Insiders. The policy, in addition to defining a conflict of interest, shall address: (a) avoidance of conflicts of interest and breaches of fiduciary duty, and the appearance of conflicts of interest; (b) involvement in the loan approval process of Insiders who may benefit directly or indirectly from the decision to grant credit; (c) disclosure of actual and potential conflicts of interest to the Board, and periodic disclosure of “"related interests” " as defined by 12 C.F.R. Part 215; (d) requirements for arms-length dealing in any transactions by Insiders, or their related interestsorganizations, involving the Bank’s 's sale, purchase, or rental of property and services; (e) disclosure of any Insider’s material interest in the business of a borrower, a loan an applicant, or other customer of the Bank; and (f) restrictions on and disclosure of receipt of anything of value by Insiders, directly or indirectly, from borrowers, loan applicants, other customers, or suppliers of the Bank. (2) Upon adoption, a copy of this conflict of interest policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) Within sixty (60) days, the Board Compliance Committee shall conduct a review of the Bank’s 's existing relationships with its and its holding company’s directors, executive officers, affiliates, principal shareholders, employees and their related interests for the purpose of identifying relationships not in conformity with the policy. The Board shall ensure that: (a) any nonconforming relationships are brought into conformity with the policy within sixty ninety (6090) days; and (b) that within sixty ninety (6090) days the Bank is properly reimbursed for: (i) any excess or improper payments to Insiders and their related interests; and (ii) any excess or improper payments for services provided by Insiders and their related interests. (4) Thereafter, the Board shall review all proposed transactions, or modifications of existing relationships, between the Bank and any of its or its holding company’s directors, executive officers, employeesaffiliates, principal shareholders, employees and their related interests. . (5) Documentation supporting these reviews shall be in writing and preserved in the Bank.

CONFLICT OF INTEREST POLICY. (1) Within sixty (60) daysBy June 30, 2001, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written, comprehensive conflict of interest policy applicable to the Bank’s and the Bank’s holding company’s directors, principal shareholders, executive officers, affiliates, and employees (collectively, “Insiders”) and related interests of such Insiders. The policy, in addition to defining a conflict of interest, shall address: (a) avoidance of conflicts of interest and breaches of fiduciary duty, and the appearance of conflicts of interest; (b) involvement in the loan approval process of Insiders who may benefit directly or indirectly from the decision to grant credit; (c) disclosure of actual and potential conflicts of interest to the Board, and periodic disclosure of “"related interests” " as defined by 12 C.F.R. Part 215; (d) requirements for arms-length dealing in any transactions by Insiders, or their related interestsorganizations, involving the Bank’s 's sale, purchase, or rental of property and services; (e) disclosure of any Insider’s material interest in the business of a borrower, a loan an applicant, or other customer of the Bank; and (f) restrictions on and disclosure of receipt of anything of value by Insiders, directly or indirectly, from borrowers, loan applicants, other customers, or suppliers of the Bank. (2) Upon adoption, a copy of this conflict of interest policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) Within sixty The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article. (604) daysBy June 30, 2001, the Board Compliance Committee shall conduct a review of the Bank’s 's existing relationships with its and its holding company’s directors, executive officers, affiliates, principal shareholders, employees and their related interests for the purpose of identifying relationships not in conformity with the policy. The Board shall ensure that: (a) any nonconforming relationships are brought into conformity with the policy within sixty thirty (6030) days; and (b) that within sixty thirty (6030) days the Bank is properly reimbursed for: (i) any excess or improper payments to Insiders and their related interests; and (ii) any excess or improper payments for services provided by Insiders and their related interests. (4) . Thereafter, the Board shall review all proposed transactions, transactions or modifications of existing relationships, between the Bank and any of its or its holding company’s directors, executive officers, employeesaffiliates, principal shareholders, employees and their related interests. Documentation supporting these reviews shall be in writing and preserved in the Bank.

CONFLICT OF INTEREST POLICY. (1) Within sixty (60) 90 days, the Board shall adoptformally review, implementrevise (if necessary), and thereafter ensure Bank adherence to a written, comprehensive approve annually the bank’s conflict of interest policy applicable to the Bank’s and the Bank’s holding company’s directors, principal shareholders, executive officers, affiliates, and employees (collectively, “Insiders”) and related interests of such Insiders. The policy, in addition to defining Board must ensure that the policy addresses the following at a conflict of interest, shall addressminimum: (a) avoidance of conflicts of interest and breaches of fiduciary duty, and the appearance of conflicts of interest; (b) involvement in the loan approval process of Insiders who may benefit directly or indirectly from the decision to grant credit;benefit (c) disclosure of actual and potential conflicts of interest to the Board, and ; (d) periodic disclosure of “"related interests” " as defined by 12 C.F.R. Part 215; (de) requirements for arms-length dealing in any transactions by Insiders, or their related interestsorganizations, involving the Bank’s 's sale, purchase, or rental of property and services; (ef) disclosure of any Insider’s material interest in the business of a borrower, a loan an applicant, or other customer of the Bank; and (fg) restrictions on and disclosure of receipt of anything of value by Insiders, directly or indirectly, from borrowers, loan applicants, other customers, or suppliers of the Bank. (2) Upon adoptionBoard approval, a copy all Directors and employees shall be required annually to certify in writing the acknowledgement of this conflict of interest policy shall be forwarded to the Assistant Deputy Comptroller for reviewpolicy. (3) Within sixty one hundred and twenty (60120) days, the Board shall conduct a review of the Bank’s 's existing relationships with its Bank or holding company’s directors, executive officers, affiliates, principal shareholders, employees and their related interests for the purpose of identifying relationships not in conformity with the policy. . (4) The Board shall ensure that: (a) any nonconforming relationships are brought into conformity with the policy within sixty thirty (6030) days; and (b) that within sixty thirty (6030) days the Bank is properly reimbursed for: (i) any excess or improper payments to Insiders and their related interests; and (ii) any excess or improper payments for services provided by Insiders and their related interests. (45) Thereafter, the Board shall review all proposed transactions, or modifications of existing relationships, between the Bank and any of the Bank’s or its holding company’s directors, executive officers, employeesaffiliates, principal shareholders, employees and their related interests. Documentation supporting these reviews shall be in writing and preserved in the Bank. (6) Upon approval of the policy by the Board, a copy of the policy should be submitted to the Assistant Deputy Comptroller for review and prior determination of no supervisory objection.

CONFLICT OF INTEREST POLICY. (1) Within sixty (60) daysBy November 30, 2007, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written, comprehensive conflict of interest policy applicable to the Bank’s and the Bank’s holding company’s directors, principal shareholders, executive officers, affiliates, and employees (collectively, “Insiders”) and related interests of such Insiders. The policy, in addition to defining a conflict of interest, shall address: (a) avoidance Avoidance of conflicts of interest and breaches of fiduciary duty, and the appearance of conflicts of interest; (b) involvement Loans to Insiders, and immediate family members; (c) Involvement in the loan approval process of Insiders who may benefit directly or indirectly from the decision to grant credit; (cd) disclosure Disclosure of actual and potential conflicts of interest to the Board, and periodic disclosure of “related interests” as defined by 12 C.F.R. Part 215; (de) requirements Requirements for arms-length dealing in any transactions by Insiders, or their related interestsorganizations, involving the Bank’s 's sale, purchase, or rental of property and services; (ef) disclosure Disclosure of any Insider’s material interest in the business of a borrower, a loan an applicant, or other customer of the Bank; and (fg) restrictions Restrictions on and disclosure of receipt of anything of value by Insiders, directly or indirectly, from borrowers, loan applicants, other customers, or suppliers of the Bank. (2) Upon adoption, a copy of this conflict of interest policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) Within sixty The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article. (604) daysBy November 30, 2007, the Board or Board Committee shall conduct a review of the Bank’s 's existing relationships with its and its holding company’s directors, executive officers, employees affiliates, principal shareholders, employees, and their related interests for the purpose of identifying relationships not in conformity with the policy. The Board shall ensure that: (a) any Any nonconforming relationships are brought into conformity with the policy within sixty thirty (6030) days; and (b) that within Within sixty (60) days the Bank is properly reimbursed for: (i) any Any excess or improper payments payments, including expenses reimbursed, to Insiders and their related interests; and (ii) any Any excess or improper payments for services provided by Insiders and their related interests. (45) Thereafter, the Board shall review all proposed transactions, or modifications of existing relationships, between the Bank and any of its or its holding company’s directors, executive officers, affiliates, principal shareholders, employees, and their related interests. Affected parties must abstain from all bank decisions related to their credit relationships. Documentation supporting these reviews shall be in writing and preserved in the Bank.

CONFLICT OF INTEREST POLICY. (1) Within sixty (60) days, the Board shall adopt, implement, adopt and thereafter ensure Bank adherence to implement a written, comprehensive conflict of interest policy applicable to the Bank’s Bank s and the Bank holding company s directors, executive principal shareholders, officers, and employees (collectively, “Insiders”( Insiders ) and related interests of such Insidersinsiders. The policy, in addition to defining a conflict of interest, shall address: (a) avoidance of conflicts of interest and breaches of fiduciary duty, and the appearance of conflicts of interest; (b) involvement in the loan approval process of Insiders insiders who may benefit directly or indirectly from the decision to grant credit; (c) disclosure of actual and potential conflicts of interest to the Board, and periodic disclosure of “"related interests” " as defined by 12 C.F.R. Part 215; (d) requirements for arms-length dealing in any transactions by Insidersinsiders, or their insider-related interestsorganizations, involving the Bank’s 's sale, purchase, or rental of property and services; (e) disclosure of any Insider’s material interest in the business of a borrower, a loan an applicant, or other customer of the Bank; and (f) restrictions on and disclosure of receipt of anything of value by Insidersinsiders, directly or indirectly, from borrowers, loan applicants, other customers, or suppliers of the Bank. (2) Upon adoption, a copy of this conflict of interest policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) Within sixty one hundred twenty (60120) days, the Board shall conduct a review of the Bank’s 's existing relationships with its and its holding company s directors, executive officers, affiliates, and principal shareholders, employees and their related interests for the purpose of identifying relationships not in conformity with the policy. The Board Bank shall ensure that: (a) bring any nonconforming relationships are brought into conformity with the policy within sixty (60) days; and (b) policy. The Board shall require that within sixty (60) days the Bank is properly reimbursed for: (ia) any excess or improper payments to Insiders insiders and their related interests; and (iib) any excess or improper payments for services provided by Insiders insiders and their related interests. (4) . Thereafter, the Board shall review all proposed transactions, or modifications of existing relationships, between the Bank and any of its holding company s directors, executive officers, employeesand principal shareholders, employees and their related interests. Documentation supporting these reviews shall be in writing and preserved in the Bank.