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Annual Policy Reviews
Question: We are struggling with the annual policy review. I hear that some examiners insist that all policies should be reviewed and adopted by the board annually. Others seem to be more relaxed about policy reviews. What is your advice?
Answer: Most examiners look for an annual policy review. We don't disagree. There is a great deal to be gained in an annual policy review. First, staff reviewing the policy must give attention to whether new products or changes in procedures should be reflected in the relevant policies. Reviewing the policies annually ensures that these comparisons are made.
Second, taking policies to the Board is an opportunity to capture the Board's awareness and increase - by a little bit - their understanding of issues. Presenting policies and identifying any recommended changes is an opportunity to communicate.
That being said, it is all too easy to overwhelm the Board with policy homework. The process should be managed carefully to use only a reasonable amount of time. You can accomplish this by grouping related policies together for presentation or even combining several policies into one. For example, a fair lending policy can include Regulation B, the Fair Housing Act, Fair Credit Reporting, and aspects of the Americans with Disabilities Act. That's one policy and one briefing instead of four.
Copyright © 2003 Compliance Action. Originally appeared in Compliance Action, Vol. 8, No. 3, 2/03
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