We are not aware of specific guidelines concerning the number of employees that a bank’s trust department should employ. The FDIC’s Trust Examination Manual requires banks to “employ a sufficient number of qualified employees” but does not provide guidance as to what number might satisfy this directive, other than to say “the staff should be adequate to handle the volume of work.” Essentially, the number of employees necessary to operate a trust department will depend on the size and complexity of the bank’s trust business.

For resources related to our guidance, please see:

• FDIC Trust Examination Manual, Section 1 — Management (Subsection D.1 – Management Appraisal, Trust Officer Duties and Management Skills, Staffing – “Management should employ a sufficient number of qualified employees. This involves effectively recruiting, training, and retaining employees.”)

• FDIC Trust Examination Manual, Section 1 — Management (Subsection D.3 – Management Appraisal, Personnel, Staffing Levels, and Authority Lines – “The staff should be adequate to handle the volume of work. Lines of authority, duties, and responsibilities should be clearly defined . . . .”)