Are there any bank policies that have to be approved on an annual basis?

As far as I know they all do. And even if the law does not require annual review the FDIC sure does.

We take all of our bank policies to the Board of Directors for approval annually.

We do too!

Few require an annual approval. I couldn't tell you which do because it isn't worth looking up. Here is the philosophy on annual approvals. Even if there are no changes, having the board reapprove/reaffirm them says that this is still valid and is still the direction we are heading.

Many banks will either do them all at once, or partition them into monthly, quarterly or semiannual chunks, depending on the time available to present and discuss them.

I used to put them all together in October or November as an example, and the board would be notified that they'd be presented in December. They had all that lead time to review them and ask questions, so the motion at the actual meeting wasn't labor intensive.

We divide ours into "pieces" and give the directors several policies at each meeting. They are divided according to length and/or complexity -- i.e. a bunch of the little, short, not-very-often changed ones together, and then the more difficult ones in smaller groups. The examiners have never complained about this system, to my knowledge.

There is no one way to do this, broken out over the year or in one chunk as Andy did with sufficient lead time for directors to review. Either is acceptable.

What is bad is to bring in to board meeting for a rubber stamp approval with no time for directors to review/discuss/ask questions.

We spread our policies out over the year. I try to group certain ones, i.e. all BSA related in one shot or all IT related.

We do have two policies on an 18 month rollover and have not had examiners sniff at the decision - Record Retention and RTFPA policy statement. As well I jsut had to do two policies that are extremely narrow in focus and impact but the examiners want everything going to the boards these days. I've drafted them to allow fpr an 18 month cycle as well. Of course if some new Reg comes up that impact these, then we will go to the board with the changes.

As an aside, we have many policies to present and the number is growing. Are you finding yourselves in the same situation??

We have a LOT of policies -- in the neighborhood of 40, and increasing all the time. Our board already feels overburdened and I, as the board secretary, hate to give them anything else to deal with. But I have no choice.

How do you deal with the various Regulations such as Z, RESPA? Do you write individual policies for approval or are they included in the general loan policy?

Specific regulations generally have a procedure, not a policy.

The "policy" about compliance with regulations is often covered in a "compliance program" that is board approved.

Certain high profile regulations/laws vary from this rule of thumb (flood, appraisals, BSA, and such) which require (or prudence calls for ) board approval for a "program".

Thank you Kathleen.

We have some policies go to the Board each month. If the policy is longer than 2 pages, we add either a footnote or a summary of the changes made "from what/to what" so the directors can be fully aware of the actual changes.