I'm curious, do most of your banks have a BSA policy and separate BSA procedures? I'm revising our current BSA policy and it encompasses both procedures and policy and is very long. I'd like the policy to be an overview of what our procedures our and separate the two.

It's much more efficient to keep broad policy statements separate from the minutia of procedures. The former get board scrutiny, but if you don't want board members to be micromanaging (or doze off in board meetings), you don't want them involved in day-to-day procedural matters.

I absolutely agree with John on this. I recommend you read the article we wrote on this topic entitled "Policies, Procedures and Processes". You can find it at our website:
http://www.bankerscompliance.com/compliance-resources/free-downloads.htm

We have separate policy and procedures because as John said, Policy is approved by the Board and procedures arent. As long as they are separate you can make changes to your procedures as they occur instead of having to take it to the Board everytime you have a change.

Our Board does not want to be involved in the day to day procedures, just the overall process.

In a prior life when I was responsible for drafting our policies and procedures, I segregated the policy statement as the first section of the BSA/AML Policies and Procedures manual. I kept a copy of a Secretary's Statement documenting the most Board review/approval with the policy. It was very easy to pull the policy and Board confirmation for review by auditors and examiners when needed.

We have a manual that maintains, in one location, our BSA related policies (BOD Approved), Programs and Procedures as well as the BSA Exam book. The manual are broken into the 4 "Pillars" + "CIP" by separate tabs. Each member of our BSA Committee has their own copy for ez reference; the examiners love this as it gives them what they need in one location, and shows the bank treats BSA seriously.

Ditto to all above. Our Policy/Program document is 5 pages long. Each business unit has written procedures on how they are going to meet compliance with the Program, and then they each have training materials that train staff on how they will meet compliance.

The Policy/Program takes care of our OFAC and AML program requirements. It is reviewed and updated annually, based recommended suggestions from Auditors and examiners and changes in processess.

Lori