I hate to see unanswered posts. It's of little help that I can't recommend anything, but on the other hand, as a small community bank, what we had was what we needed, based on our risk assessments and track record and simply was a variance created in-house based on examiner workpapers and the people we had to do this. It's difficult to find a "one size fits all" solution.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell