lately, every time our friends come up with guidance or some other ruling, we appear to jump to the conclusion that we need to have a policy statement. thats a lot of statements going to the board. What about having in depth procedures and then mentioning RDC as part of the info in an E-banking policy statement, that already goes to the board and which will refer to the RDC procedures?

I would think you could have it as part of your Ebanking Policy, but there are some specifics you would want to make sure you address i.e. roles and responsibilities, risk management, vendor management, contract/agreement requirements, limits on who it is offered to, etc. I would make it a separate section in the Ebanking Policy if that is the direction you choose to go.

I love the suggestion. A perfect location.