Hi everyone - we're just about ready to send our "substantially modified" BSA, with the CIP as an attachment, to the Board for approval. Of course, all the VP's want to take a look at it first, and the initial comments we're getting is that it's "too long".

We already cut our original draft CIP from 9 pages to 6 before we sent it to them. They want to hack and slash and cut it down to a nice little 1-2 pages.

So - I'm just wondering how many pages your CIP's are turning out to be? Is 6 pages unreasonably long? With all the "shall include" items in there, we didn't see how we could cut it much from where it is now...

We separated the policy from procedures (program). Policies should generally state your intention to comply with whatever regulation it addresses. Procedures (program) should be specific in how you will apply the regulation. We incorporated the CIP policy into the BSA & AML policy. The procedures for each are separate.

Our CIP is seperate from our BSA policy but under the BSA program as a whole. Our entire CIP (which is both policy and procedure) is 8 pages plus 2 attachments for a total of 10.

Today our CIP is 10 pages. Tomorrow??? It is both policy and procedure. It is separate from BSA policy but will be part of the BSA program.

We are just putting the finishing touches on ours, as an addition to the BSA policy, the CIP is seven pages.

I'm with Ahou - policy is separate and about 2 pages long. We don't want to have to change the policy everytime we change a procedure. The Board normally approves policy annually and I don't want to tell them this is the 5th time we need them to approve our policy this year.

Mine was 5 pages this morning, but after looking at the CIP checklist from BOL Tools, it has ballooned to 9 pages and an appendix. Help Me! Help Me!

Bank Secrecy Act 14 Pages
Customer Identification Program 10
Risk Assessment 3

Our CIP was 7 pages. Originally it was much longer since there were procedural items in there. I believe the procedure stands by itself now, supported by the policy. BSA is a separate policy for us.

Ours is 11 including the notice language and 2 pages of flow charts...one personal and one business.

The examiners will not be counting pages, they will be looking at substance. If my institution will only open accounts for new customers at the branch, compared to your institution that opens accounts via the mail, telephone or the Internet your policy should be longer. Look at the number of branches, your location, your product offerings.

I need some clarification: Does the Board have to approve your BSA Policy (usually a 1 - 3 page document) or does it have to approve the BSA Program, which would include procedural informaton as well, and could easily be a 50 page document? I think it is clear that the CIP that goes to the Board is both policy and procedure, but what about the BSA? Thanks for clarifcation...and is anyone working today??? Friday before a Monday Holiday is like a ghost town around here.

Quiet Friday, but I'm still here!

The Board has to approve any "material" changes to your BSA Policy. CIP is now defined as part of BSA. So the addition of a CIP requires a material change to your BSA Policy.

Most of us are adding a line or two to the BSA Policy document, incorporating the CIP by reference, and then writing up all the stuff the Reg says "the CIP must include..." as an attachment / addendum to the BSA Policy.

Both pieces have to be presented to the Board for approval - with the CIP in sufficient detail for the Board to be able to determine that you will be meeting all the requirements and are able to "form a reasonable belief that [you] know the true identity of the customer."

Ground-level procedures do not need Board approval, just the high-level policy (and the few specifics required by the Reg). Let your unit managers design their detailed procedures to fit into your policy. They know what works best for their staffs and can adjust if it's not working.

Our BSA piece is only 2 pages, and the CIP is currently at 6 pages. I know the auditors won't care how long it is - they'll probably think the longer, the better so everything gets covered - but the VP's (who want to stick their fingers in the pie before it gets to the Board) are complaining that it's too long...