This thread makes me rethink a part of our periodic reporting to the Board. Our report to the board includes a list of newly exempted names, just as an FYI, to explain what has been done in that arena since the previous report. I wonder if that constitutes tacit board approval, since the board does not take issue with the information provided in that section.
BTW, I've found in other areas that the state's understanding of BSA issues is very different from the federal regulator's understanding. Terminology used in the state's request list has been confusing and has not always applied to the situation or the requested item. I just provide them the closest thing I can think of that they are asking for, and they haven't complained. For that request item, I would simply provide them a copy of the exempt list, and not mention that it was or was not board-approved. If they later came back and said "Where's your board approval?" that's when I would explain that nothing in regulation or FI policy requires board-approval.
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"It is natural to give a clear view of the world after accepting the idea that it must be clear." - Albert Camus