I know this has been discussed previously and there may not be a legal requirement to have policies reviewed and approved by the BoD on an annual basis. However, I was wondering what other banks are doing for this?

Any feedback would be greatly appreciated.

Truthfully, I liked the way my prior bank handled this. All of the policies were on a "calendar." The officer responsible for that policy got an e-mail asking him to review and see if any changes were necessary. There was a standing agenda item for the BOD to review all of these non-changed policies. They were sent out in advance with a cover sheet that bullet-pointed what the policy was for, some highlights of it, their responsibilities and any other info the resp officer wanted to include.

There was also a standing agenda item to look at changes to policy requiring their approval.

It worked for us and the BOD felt informed and engaged without feeling overwhelmed by policy reading.

Was that the info you were looking for? Short on coffee this am so call me out if I misread your question.

We also keep a shared spreadsheet of policies and when they were last reviewed/approved by the board. It is the policy owner's responsibility to keep their entries updated as to when they were last approved.

Excellent concept!

Thanks for the feedback guys. Policy tracking is centralized with me, but the policy owner is on the hook for updating the policy. What I'm curious about though is, if a policy is approved in December 2014 and there are no revisions, is the policy sent back to the BoD for approval in December 2015? Can it be pushed to June 2016? Maybe even when the next revisions are made?

We keep a calendar tracker of all policies and present them for annual renewals regardless of whether there are changes or not. If I recall correctly, this was an audit mention. I send reminders to the responsible parties in advance of the renewal so the policies can be refreshed if necessary.

Once a year even if no changes. So, in your example, we would put it on the calendar for sometime in 2015. Chief Lending Officer would review for updates, changes, whatever, and the BOD would review. The owner of the policy (CLO in this example) could send in July 2017 with changes to be approved. And then back into the regular rotation for 2018.

Worked at my last bank very well. All were happy. We are still inventing that wheel here.

Sidenote: Welcome, ocbeach. I hope that's short for Ocean City!

I know of one bank that has all policies changed or recertified by departments as of 12/31. They are then put on a CD for all directors to review for certification at the February meeting.

Also IMHO, to keep things easy, policies are the "what". Procedures are the "who", "when", "where" and "why", and should include functional titles rather than names in the event someone changes or moves on.

If there's not a requirement to annually approve a policy, it's not necessary to annually review/approve them. It's that simple.