For reasons I won't go into, I am faced with the proposition of starting from scratch in creating a new BSA policy/program and procedures.

I'm thinking that perhaps the best way to approach this is to use the exam procedures core overview to create policy sections, and then write the policy according to the exam procedures. Then I would write bank procedures based on the policy. Does that make sense? Or is there a better way to tackle this project?

Oh, and it all has to be complete and in place by the end of August . . .

Sounds reasonable to me. I think using the exam procedures is the best way to go. If you address all of the points in the exam, I can't imagine the examiners giving you a hard time.

Does anyone have the procedures in a Word doc that you could share with me, as I am having problems opening the pdf file.
You can email it to: perthwa@aol.com
Thanks.

When faced with a blank piece of paper it's always helpful to have a "go by," something you can use as a reference to organize your thoughts. To me, the BSA exam procedures have always been the best possible resources for developing policies and procedures. First, there is no point in inventing the wheel. Second, they will appear familiar to the regulators. Finally, even though it sounds like your attentions are "forced," there has never been a more appropriate time for banks to take a fresh look at BSA.

As you suggest, go through the exam procedures and list the major issues the policy should address. Under each major heading list the procedures that are necessary to implement the goals. Remember, policies focus on "why." Procedures focus on who, what, when, where and how.

Many banks have BSA related policies and procedures that reflect a series of documents spliced together over the last 18 years. They read and work accordingly. Yours is going to be comprehensive and reflect the current perspective on every issue.

Thanks for your comments! This will be a painful and time consuming process but it will be good to have it done.