Question & Answer
Question: We have a lot of compliance policies. Some board members have questioned whether we really need all these policies. Are they all needed, or can we combine some policies to cover the regulatory requirements but have fewer documents?
Answer: As to having policies for all of the regulations, yes, you should. However, they do not necessarily need to be separate documents, one policy per regulation. You could combine some of them into single policies. To do this, you should base any combination on common denominators.
For example, you could have a consumer complaint and inquiry policy that establishes the bank's general policy and procedures for handling consumer complaints, but also includes specific regulatory requirements such as those in Regulations E and Z.
Policies for many of the loan-related regulations could be combined into the bank's lending policy. You could also have broad-scoped policies for account opening, and teller transactions.If you take this approach, you should be very careful to track all regulatory requirements. In fact, to make things easier for the examiner, you might keep a chart of where to find the policy for different regulations.
Copyright © 1998 Compliance Action. Originally appeared in Compliance Action, Vol. 3, No. 13 & 14, 10/98
First published on 10/01/1998