BOLI, Bank Owned Life Insurance
In the world of community and commercial banking, there is a fundamental truth that every Board of Directors eventually faces: your most valuable assets don't show up in your vault; they sit in your executive offices. The talent you've spent years cultivating is the engine of your growth, yet the cost of retaining that talent, specifically through competitive retirement packages and benefits, can create a significant drag on your earnings.
If you are a bank executive or a board member, you likely find yourself asking some variation of the "Five What Ifs" that keep leadership up at night. What if our top talent leaves for a competitor? What if the cost of replacing a senior executive erodes our quarterly margins? What if our current benefit structures are no longer cost-effective in a shifting interest-rate environment?
This is where Bank Owned Life Insurance (BOLI) moves from a technical financial product to a strategic cornerstone. At Schiff Executive Benefits, we believe in Restoring Alignment and Retention by using BOLI as more than just a policy, it's a way to reverse-engineer the financial security your institution needs.
What is BOLI and How Does It Work?
At its simplest, BOLI is a form of life insurance purchased by a bank on the lives of its key employees (usually the top 35% of the workforce, though often focused on the executive suite). The bank is the owner and the beneficiary of the policies.
However, BOLI is not "insurance" in the traditional sense you might think of for your personal estate. It is an earning asset. When you purchase BOLI, you are effectively reallocating a portion of the bank's low-yielding liquid assets into a specialized insurance contract that offers significantly higher after-tax yields.
The mechanics are elegant in their simplicity:
- The bank pays a single premium (or a series of premiums) to an insurance carrier.
- The cash surrender value (CSV) of the policy grows on a tax-deferred basis.
- This growth is recorded as "Other Non-Interest Income" on the bank's income statement.
- Upon the death of the insured executive, the death benefit is paid to the bank, generally income tax-free.

The Regulatory Landscape: Navigating OCC 2004-56
You cannot discuss BOLI without discussing the regulatory framework that governs it. For national banks, the primary guidance is OCC Bulletin 2004-56, which transmits the Interagency Statement on the Purchase and Risk Management of Life Insurance.
The regulators, including the FDIC and the Federal Reserve, are not opposed to BOLI; in fact, they recognize it as a permissible "incidental" activity. However, they demand a high level of due diligence. They want to see that you didn't just "buy a product," but that you engaged in a rigorous pre-purchase analysis.
This analysis must document:
- The Business Purpose: Why are you buying this? (Usually to offset the cost of employee benefit obligations).
- The Size of the Obligation: You must quantitatively tie the BOLI amount to the present value of the benefits you are funding.
- Risk Management: You must assess credit risk, interest rate risk, and liquidity risk.
As someone who helped draft the regulations surrounding IRC 409A and 101(j) during my time on the AALU's NQDC Committee, I have seen firsthand how important it is to be "in the room where it happened." We design our BOLI programs to be "bulletproof" from a regulatory standpoint because we understand the intent behind the laws, not just the text on the page.
BOLI as a Strategic Balance Sheet Asset
Why do banks choose BOLI over traditional investments like Treasuries or municipal bonds? It comes down to the after-tax yield and the impact on the balance sheet.
In a typical taxable investment, your yield is eroded by corporate income taxes. With BOLI, because the internal buildup of cash value is tax-deferred (and often tax-free if held until death), the tax-equivalent yield is substantially higher. It is not uncommon for a BOLI portfolio to outperform traditional bank-allowable investments by 150 to 250 basis points on an after-tax basis.
Furthermore, BOLI provides:
- Immediate Accretion to Earnings: Most BOLI policies are structured so that the first-year increase in cash value exceeds the premium's opportunity cost, providing an immediate boost to non-interest income.
- Stability: BOLI returns are generally less volatile than the equity markets, providing a "bond-like" stability to the long-term asset side of your ledger.
- Tier 1 Capital: BOLI is often treated as a Tier 1 asset, supporting the bank's capital adequacy ratios.

Funding SERPs and Retaining Top Talent
While the balance sheet benefits are compelling, the true power of BOLI is realized when it is used to fund Supplemental Executive Retirement Plans (SERPs).
A SERP is a nonqualified plan that provides benefits to key executives above and beyond what is allowed in a 401(k). The problem for many banks is that a SERP creates a growing liability on the books. BOLI acts as the "informal funding" vehicle that grows alongside that liability.
By using BOLI to fund a SERP, you are able to:
- Attract the Best: Offer retirement packages that compete with much larger regional or national banks.
- Retain the Best: Use "golden handcuffs" to ensure your key leaders stay through their peak earning years.
- Reward Performance: Structure benefits that trigger only when the bank hits specific growth or stability milestones.
When we talk about Perfect Plan®, we are talking about this exact alignment, where the bank's financial health and the executive's personal security are perfectly synced.
Why the Consultant Matters: The SEB Difference
There are plenty of people who will sell you a BOLI policy. But BOLI is not a "set it and forget it" product. It requires ongoing monitoring, annual reviews, and technical expertise that most internal HR or finance departments simply don't have the bandwidth to maintain.
At Schiff Executive Benefits, we pride ourselves on being independent. We are brokers, which means we work for you, not the insurance carrier. We have the ability to work with any carrier in the marketplace to find the specific product that fits your bank's culture and intent.
Our approach is one of Goal-Oriented Reverse Engineering. We don't start with a product; we start with your "What Ifs." We look at your existing advisors, your accountant, your attorney, your TPA, and we work alongside them as a specialized technical resource.
With almost 100 years of combined experience, we've seen every market cycle and every regulatory shift. We know how to ensure your program complies with IRC 101(j) and remains a safe-and-sound asset for decades to come.

Take the Next Step for Your Institution
Is your bank's current benefit strategy optimized? Are you using the most efficient assets to protect your bottom line?
If you're ready to see how BOLI can transform your balance sheet while securing your leadership team, we invite you to sit back, grab a coffee, and let's talk. A great place to start is by understanding the true value of your business and the risks you face.
Click here to use our Business Valuation tool and start capturing the data you need to plan for the future.
You can also explore our latest insights on bank-owned life insurance or learn more about benchmarking your current strategy to ensure you aren't leaving money on the table.
Frequently Asked Questions
What is the maximum amount of BOLI a bank can hold?
Generally, regulators look for BOLI holdings to be no more than 25% of the bank's Tier 1 Capital plus the allowance for loan and lease losses (ALLL). However, this can vary based on the bank's overall risk profile and the quality of the insurance carriers.
Is BOLI a liquid asset?
BOLI is considered a long-term, relatively illiquid asset. While the cash value can be accessed through surrender, doing so often carries significant tax penalties. Therefore, it should only be funded with "permanent" capital that the bank does not expect to need for short-term liquidity.
How does BOLI impact our taxes?
The growth of the cash surrender value is tax-deferred. If the policy is held until the death of the insured, the proceeds are typically received income tax-free. This creates a very high tax-equivalent yield compared to taxable investments.
Who owns the BOLI policy?
The bank is the 100% owner and beneficiary. The employee has no claim to the cash value or the death benefit unless the bank chooses to share a portion of the death benefit with the employee's family as part of a split-dollar arrangement.
Does BOLI require employee consent?
Yes. Under IRC 101(j), banks must obtain written consent from employees before the policy is issued. This is a critical compliance step that we manage as part of our implementation process.





![[HERO] Abstract technical business dashboard with financial charts, data layers, and analytical visuals, emphasizing the balance sheet structure and quantitative role of COLI.](https://cdn.marblism.com/UJd8h-ZgZ8P.webp)
![[HERO] Abstract analytical business interface with layered charts, financial metrics, and technical data visualization, reflecting the investigative and compliance-driven structure of COLI.](https://cdn.marblism.com/m1owd8y8FuJ.webp)
![[HERO] Technical financial analytics scene with structured reports, chart overlays, and corporate data review visuals, reinforcing the cost recovery mechanics behind COLI.](https://cdn.marblism.com/5rtqWRkDWGx.webp)
![[HERO] Close-up technical business visualization with financial graphs, reporting layers, and strategic data analysis elements, underscoring the quantitative planning behind COLI.](https://cdn.marblism.com/eOfFgUurYHS.webp)

































