My questions are dealing with the creation and delivery of your loan policies and procedures - all of them from Reg. B to Reg. Z related.
1. Do you create them on a specific software program? Word? Procedure Write? Other?

2. Do you separate your loan policies from your procedures, or are they interwoven?

3. Do you make them available in all of your branches in hard copy? Just on your intranet? Both?

4. Which creation and delivery methods do you prefer? Does your staff prefer?

Any input would be appreciated! Thank you!

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The opinions expressed are not necessarily those of my employer.

A few years ago we wrote both a Loan Policy Manual and a Loan Procedures Manual. Both were created in Word. What we did was have the parties involved write the sections relevant to them - for example, Credit Admin wrote the credit section, retail banking wrote more of the procedures for consumer loans, etc. Then one person, someone's lucky assistant, put all of the files together in 'procedure' format with a table of contents, etc. Each branch location/lender has a copy of both manuals. On our Intranet we have quick procedures and reference guides -- things that are more likely to be used on a day to day basis in the course of dealing with a customer. I think that is used quite frequently - the actual manuals probably only when someone needs to do some research. Hope this helps.

Sue Norton
Opions expressed are not necessarily those of my employer.

Thanks Sue! Yes, we had ours written since the beginning of time - updated annually. They are actually very good - just very lengthly since we are bound by so much regulation. The difficult thing is making it fit to this new format/software. It works really well for procdure, not so well for policy. But, using it just for a quick guide may be a solution - something I hadn't thought of.

I have some strong opinions on developing policies and procedures, having observed what works and doesn't work in lots of situations.

First, examiners know boilerplate when they see it. Buying a pre-fab job is not the best idea. It doesn't impress examiners and, more importantly, it doesn't get the job done.

My favorite technique is the process Sue described. Building procedures from the job-doers accomplishes several important things. The biggest is their buy-in to the result. They built it and they are likely to use it. It also ensures that the procedures developed are accurate and workable -- not a guarantee for a purchased set of procedures. Finally, it involves a lot of people in the process and serves as a major component of training -- actually getting people to sit down and think through compliance requirements and how to get them done.

I am also a proponent of blended procedures. If you separate compliance procedures from other procedures, the compliance books will go unused while the other procedures get dog-eared.

The best part about this team approach is that you get other people to do most of the work and they'll thank you for it!

Yes, I agree. Our policies and procedures are already written - and very good. Our problem is converting what is good to this new format. This new delivery format basically wants a more bullet point format, and I don't think that's possible with our loan policy which is mostly text. So, I'm looking for more format and delivery advice as opposed to how best to write a policy.

[This message has been edited by Buffy D (edited 03-28-2001).]

Your policy, board approved, may be somewhat of an overview where possible. That would thin them down. The weight would then be transferred to the procedures.

I separate policy form procedure because while the board approves policy, management approves procedure. I have seen procedures that were specific down to the screen prompts. These were used for real training and so a newbie could step in and do a task with that as a manual. Well, if any small thing changed, (in my mind) if the board approved it, the board has to change it.

Separating the two afford us flexability.

As to the program, whatever you use now is what I'd use so long as I could develop templates for a consistent look and feel.

The first loan policy I saw at my old bank was about 500 pages long. And I mean l o n g. So that changes could be made, the author didn't put page numbers on it. Who would have thought about adding a ".1" or ".2"? Not him. Biggest waste of time you ever did see. That pre-dated the PC so there was no editing.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

I recently went to our computer consultants with this question. I created the files in Word, they created the files in pdf format for me to e-mail to everyone and now we can pull them up, search, go to the correct section of the loan policy manual or the actual compliance policies. When I make changes, I e-mail the changes to them, they incorporate the change and I e-mail a new version to the employees. It has eliminated copying and the problem of " I don't have that in my manual"

I didn't think you could search a document that is in PDF format. Could anyone share how to do it?

To search a PDF file, use the binoculars in the Adobe toolbar. It's the find tool.

You may need Acrobat 4.0 or later to search in PDF formatted files.

Our bank is a strong advocate of putting policy and procedures manuals on our intranet (we use Lotus Notes). That eliminates having to have employees doing the old page swapping thing. We do send a general e-mail when we have any substantive change, just to make sure affected people know to look.

I really like Lucy's suggestion that procedures be inclusive rather than separate. But I tend to prefer segregating policies (general, board approved) from procedures (specific, management approved and employee-generated).

Our bank has combined policies and procedures, which I believe is more useful for training and a resource for compliance requirements. It is a very user friendly guide that is in Word and broken out by sections: policies, mortgage lending products, pre-application, initial application process, completing the application process, loan underwriting, post underwriting, closing, and miscellaneous (i.e., compliance matrix, penalties, record retention, glossary). We were able to use bullet points throughout much of the manual, which makes it much easier to read than text. For example, the nondiscrimination prohibited bases can be bulleted. There has been a very positive response to the new format.