I've read through the SAFE Act rules and did not see anywhere that this is one of the bank policies that needs to be approved by the bank's board of directors.

Is it sufficient to have this policy approved by senior bank management or is board approval required?

Thanks.

I'm pretty sure that any POLICY requires board approval. In my opinion, unless unusal circumstances, board should not approve procedures. If they do, then every time there is a change in procedure (and there will be....) you'd have to have board approval.