A provision buried in the regulatory burden act's section on "Regulatory Micromanagement Relies" requires the bank regulatory agencies to review requirements for internal written policies to identify outmoded or duplicative regulations and policies that can be eliminated. Titled "Paperwork Reduction Review," section 2242 directs the bank regulatory agencies to review the extent to which existing regulations require banks and credit unions to produce "unnecessary internal written policies." Such requirements should be eliminated, where appropriate.
Whether this provision really produces any burden relief remains to be seen. The agencies still have the discretion to determine whether the required policies are "necessary." Most regulators think that they are.
Bright Idea: Institute a compliance award to recognize someone who has done something notable in the eyes of a compliance manager. For example, a loan officer who never makes a mistake, or a staff member who made a really good suggestion to improve procedures' and compliance performance. Let somebody get something good from compliance!
Copyright © 1996 Compliance Action. Originally appeared in Compliance Action, Vol. 1, No. 16, 10/96
First published on 10/01/1996