Management and Board Oversight
The conservative use of BOLI depends on effective senior management and board oversight and administration. Regardless of an institution’s financial capacity and risk profile, the board must understand the complex risk characteristics of the institution’s insurance holdings and the role this asset is intended to play in the institution’s overall business strategy. Although the board may delegate decision-making authority related to purchases of BOLI to senior management, the board remains ultimately responsible for ensuring that the purchase and holding of BOLI is consistent with conservative banking practices.
Policies and Procedures
Consistent with prudent risk management practices, each institution should establish internal policies and procedures governing its BOLI holdings, including guidelines that limit the aggregate CSV of policies from any one insurance company as well as the aggregate CSV of policies from all insurance companies. These policies and procedures should include a pre-purchase analysis and on-going risk management.
The objective of the pre-purchase analysis is to help ensure that the institution understands the risks, rewards, and unique characteristics of BOLI. The nature and extent of this analysis should be commensurate with the size and complexity of the potential BOLI purchases and should also take into account existing BOLI holdings. A mark of a well-managed institution is the maintenance of adequate records concerning its pre-purchase analyses, usually including documentation of the purpose and amount of insurance needed.
An effective pre-purchase analysis involves the following management actions: