FDIC 6200/09 (12-19) Page 1 of 5

OMB Number: 3064-0025 

Expiration Date: 01/31/2025

Federal Deposit Insurance Corporation 

APPLICATION FOR CONSENT TO EXERCISE TRUST POWERS

DISCLOSURE OF ESTIMATED REPORTING BURDEN 

An agency may not conduct or sponsor, and an organization (or a person) is not required to respond to, a collection of information 

unless it displays a currently valid OMB control number. Public reporting for this collection of information is estimated to range 

between 8 hours (if the bank is an “eligible depository institution under 12 CFR 303.2(r)) to 24 hours for other applicants), this 

includes the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and 

completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this 

collection of information, including suggestions for reducing this burden, to the Paper Reduction Act Clearance Officer), Legal 

Division, Federal Deposit Insurance Corporation, 550 17th Street, N.W., Washington, DC 20429, and the Office of Management 

and Budget, Paperwork Reduction Project (3064-0025), Washington, D.C. 20503. An agency may not conduct or sponsor, and a 

person is not required to respond to, a collection unless it displays an currently valid OMB number. 

Page down to access form 6200/09
OMB Number: 3064-0025 

Expiration Date: 01/31/2025

FDIC 6200/09 (12-19) Page 2 of 5

Federal Deposit Insurance Corporation 

APPLICATION FOR CONSENT TO EXERCISE TRUST POWERS

SECTION I - BANK INFORMATION

1. Name of Applicant Bank

2. Street Address

3. City 4. State 5. Zip Code

SECTION II - TRUST POWERS SELECTION

6. Select the type of Trust Power for which you are applying. (Select One)

Full Trust Power Limited Trust Powers (Complete Schedule Below)

Schedule of Limited Trust Powers for which you are Applying (Select all applicable box(es))

Personal Trust

Executor and Administrator Guardian Agent

Trustee Investment Advisor Agent

Committee or Conservator Investment Management Agent

Other (Specify):

Employee Benefit Trust Powers

Trustee Investment Management Agent

Investment Advisor Agent

Agent

Other (Specify):

Custodian

Corporate Trust Powers

Trustee Agent

Escrow Agent

Pay Agent

Other (Specify):

Transfer Agent

SECTION III - PERSON(S) TO WHOM INQUIRIES REGARDING THIS APPLICATION MAY BE DIRECTED

7. Name 8. Position

9. Street Address 10. City

11. State 12. Zip Code 13. Telephone

14. Signature of CEO or Designee 15. Date

NOTE: Title 18 U.S.C. 1007 provides as follows: “Whoever, for the purpose of influencing in any way the action of the Federal 

Deposit Insurance Corporation, knowingly makes or invites reliance on a false, forged, or counterfeit statement, document, or thing 

shall be fined not more than $1,000,000 or imprisoned not more than 30 years, or both.”
OMB Number: 3064-0025 

Expiration Date: 01/31/2025

FDIC 6200/09 (12-19) Page 3 of 5

GENERAL INFORMATION AND INSTRUCTIONS 

Regulatory Requirement 

This application is used by insured state nonmember banks to request FDIC consent to exercise trust powers granted by the 

chartering state authority. Applications are required by Section 303.281 of FDIC's Rules and Regulations as a change in the 

general character of the bank's business. Activities constituting trust powers are governed by state statute, regulation, or 

policy. 

Instructions 

Complete the cover page of the application and provide a response to each item requested in the Specific Instructions section 

of this application. Any attachments will be considered a part of this application. Send the completed original application to 

the appropriate Regional Director (DOS). 

The applicant is responsible for presenting and documenting information sufficient to process the application. All questions 

must be answered with complete and accurate information that is subject to verification. If the answer is "none," "not 

applicable," or "unknown," so state. Answers of "unknown" should be explained. The informational questions in the 

application are not intended to limit the applicant's presentation. You may provide any additional information deemed 

appropriate to a complete understanding of the proposal. The FDIC may request additional necessary information. 

If any information initially furnished in the application changes materially during the processing of the application, such changes 

should be communicated promptly to the appropriate Regional Director (DOS) with which the application was filed.

"Eligible Depository Institution" 

A depository institution that meets the following criteria: (1) has been chartered and operating for three or more years; (2) has an 

FDIC-assigned composite rating of 1 or 2 under the Uniform Financial Institutions Rating System (UFIRS); (3) with regards to filings 

set forth in Section 303.5 of FDIC's Rules and Regulations, has a satisfactory or better Community Reinvestment Act (CRA) rating; 

(4) has a compliance rating of 1 or 2; (5) is well-capitalized as defined in the appropriate capital regulation and guidance of the 

institution's primary Federal regulator; and (6) is not subject to a cease and desist order, consent order, prompt corrective action 

directive, formal or informal written agreement (excluding any board of directors' resolution addressing corrective action taken 

pursuant to regulatory recommendations), or other administrative agreement with its primary Federal regulator or chartering 

authority. Section 303.2(r), FDIC Rules and Regulations [ 12 CFR 303.2(r) ]

Confidentiality 

This application will be made available to the public upon request under the provisions of the Freedom of Information Act, unless 

the information is confidential in nature and qualifies for exemption under this Act. 

In general, requests for confidential treatment of specific portions of the application must be in writing and must be submitted 

concurrently with the application. The request should specifically demonstrate the harm (e.g., to its competitive position, invasion 

of privacy) that would result from public release of information (5 U.S.C. 552). 

Information for which confidential treatment is requested should be (1) specifically identified in the public portion of the application 

(by reference to the confidential section), (2) separately bound, and (3) labeled "Confidential." The Applicant should follow the 

same procedure regarding a request for confidential treatment with regard to the subsequent filing of supplemental information to 

the application.
OMB Number: 3064-0025 

Expiration Date: 01/31/2025

FDIC 6200/09 (12-19) Page 4 of 5

SPECIFIC INSTRUCTIONS 

INFORMATION REQUIRED FOR CONSENT TO EXERCISE TRUST POWERS 

Applications from "Eligible Depository Institutions" for expedited processing should include the cover page and questions 1 

through 4 below. Applications from all other institutions for standard processing should include the cover page and all of the 

questions below. The term "eligible depository institutions" is defined in the General Instructions of this form. 

1. Adoption of Statement of Principles. Provide a certified copy of the resolution of the applicant's board of directors 

adopting the Statement of Principles of Trust Department Management. 

2. State Trust Powers. Indicate (a) the trust powers granted by the state authority, (b) the date(s) those powers were 

granted, and (c) the status of any application(s) filed with the state authority regarding the granting of, or consent to exercise, 

trust powers. 

3. Trust Officer. Identify the individual designated to be the primary Trust Officer. Indicate their age, proposed title, and 

proposed annual salary, and the percentage of time to be devoted to fiduciary activities. Indicate the candidate's current 

position and responsibilities, employment history, and business and educational qualifications in the fiduciary, employee benefit 

and tax areas. Also indicate any professional licenses or similar certificates. Note: In lieu of this descriptive information , the 

proposed Trust Officer may complete the biographical information portion of the Interagency Biographical and Financial Report.

4. Servicing Arrangements. If the institution intends to use another organization to manage the administration of its trust 

accounts and/or to manage trust investments, please provide: (a) the name, address and phone number of each such 

organization; (b) the organization's relationship (if any) to the applicant and its directors and officers; (c) the type of service(s) 

to be provided; (d) the basis for selecting each such organization; (e) whether such service(s) will be governed by a written 

agreement; (f) the projected annual cost of such service(s); and (g) how the applicant intends to monitor the outside 

organization's performance and compliance with the scope and terms of fiduciary responsibilities and the written agreement. 

Please note: This question does not cover EDP servicing or custody of trust assets by correspondent banks. 

5. Trust Committee. List proposed members of the Trust Committee and specify their trust-related experience and 

knowledge. For each person, provide: Name, position with the applicant, number of years associated with the applicant, 

principal occupation, and qualifications in fiduciary, investment, employee benefit, and tax areas. 

6. Trust Counsel. Identify the attorney or legal firm which will serve as trust counsel, and describe their qualifications in 

fiduciary matters. Provide: (a) name and location of firm [if individual attorney include name] , (b) experience in probating 

estates and administering other fiduciary business, (c) any present professional services performed for the applicant, and (d) any 

present fiduciary services performed for competing trust institutions.

7. Projection of Trust Activity. Provide a projection of trust accounts, assets, and profitability for the first three calendar years 

after the trust department begins operations. 

• Trust Accounts and Assets: As of each year-end, show the number of accounts expected to be generated, broken down by 

general type(s) of trust activity (personal trust, employee benefit accounts, corporate trust, etc.), together with the dollar 

volume of trust assets expected to be under the trust department's administration for each general type of trust activity 

• Trust Profitability: For each of the three calendar years, show gross trust account fees, other income, and a breakdown of 

direct and allocated expenses (such as salaries and benefits, audits, data processing, advertising, operations, legal, 

overhead, etc.). If the bank intends to provide an internal credit for bank earnings generated by trust deposits, the credit for 

deposits should be included as a separate item for each year. 

8. Impact on Applicant. For years where the trust profitability projections indicate a net operating loss from offering trust 

services, discuss the extent of the adverse impact of these losses on the condition of the applicant. 
OMB Number: 3064-0025 

Expiration Date: 01/31/2025

FDIC 6200/09 (12-19) Page 5 of 5

STATEMENT OF PRINCIPLES OF TRUST DEPARTMENT MANAGEMENT

The minimum requirements to provide for sound banking practices in the operation of a trust department and to provide 

safeguards for the protection of depositors, fiduciary beneficiaries, creditors, stockholders, and the public, should include: 

• Involvement by the board of directors in providing for the establishment and continuing operation of a trust department; 

• Operation of the trust department separate and apart from every other department of the bank, with trust assets separated 

from other assets owned by the bank, and the assets of each trust account separated from the assets of every other trust 

account; and 

• Maintenance of separate books and records for the trust department in sufficient detail to properly reflect all trust department 

activities. 

Nothing herein is intended to prohibit the board of directors from acting as the trust committee, or from appointing additional 

committees and officers to administer the operations of the trust department. When delegating duties to subcommittees and/or 

officers, the board and the trust committee continue to be responsible for the oversight of all trust activities. Sufficient reporting 

and monitoring procedures should be established to fulfill this responsibility. 

The board of directors, by proper resolution included in its minutes, should: 

1. Designate an officer, qualified and competent, to be responsible for and administer the activities of the trust department. In 

addition, the board should define the officer's duties. 

2. Name a trust committee consisting of at least three directors to be responsible for and supervise the activities of the trust 

department. The committee should include, where possible, one or more directors who are not active officers of the bank. 

The trust committee should:

a) Meet at least quarterly, and more frequently if considered necessary and prudent to fulfill its supervisory responsibilities; 

b) Approve and document the opening of all new trust department accounts; all purchases and sales of, and changes in, 

trust assets; and the closing of trust accounts; 

c) Provide for a comprehensive review of all new accounts for which the bank has investment responsibility promptly 

following acceptance; 

d) Provide for a review of each trust department account, including collective investment funds, at least once during each 

calendar year. The scope, frequency, and level of review (trust committee, subcommittee, or disinterested account officer) 

should be addressed in appropriate written policies which give consideration to the department's fiduciary responsibilities, 

type and size of account, and other relevant factors. 

Generally, discretionary account reviews should cover both administration of the account and suitability of the account's 

investments, and nondiscretionary account reviews should address account administration; 

e) Keep comprehensive minutes of meetings held and actions taken; and 

f) Make periodic reports to the board of its actions.

3. Provide comprehensive written policies which address all important areas of trust department activities. 

4. Provide competent legal counsel to advise trust officers and the trust committee on legal matters pertaining to fiduciary 

activities. 

5. Provide for adequate internal controls including appropriate controls over trust assets. 

6. Provide for an adequate audit (by internal or external auditors or a combination thereof) of all fiduciary activities, annually. 

The findings of the audit, including actions taken as a result of the audit, should be recorded in its minutes. 

If a bank adopts a continuous audit process instead of performing annual audits, audits may be performed, on an activity-byactivity basis, at intervals commensurate with the level of risk associated with that activity. Audit intervals must be supported and 

reassessed regularly to ensure appropriateness given the current risk and volume of the activity.

7. Receive reports from the trust committee and record actions taken in its minutes. 

8. Review the examination reports of the trust department by supervisory agencies and record actions taken in its minutes.