Can a bank provide third party review as a consultant?

We believe that the answer is yes, although there should be a strong written agreement that creates an agency relationship and provides firewalls with respect to disclosures of financial information. We’re pretty sure that a number of unrelated banks in the past few years have combined personnel for compliance purposes. Having said all that, the bank definitely should consult with their primary regulator about this — in fact, at least at the beginning, both banks should consult their primary regulators, if different.