Is it a requirement that the Bank's BOD have to approve all bank compliance policies? Perhaps specific ones?

If so/or not, where is there guidance about this?

Can it just be a management committee, who then will notify the BOD which policies have been approved?


Thanks

Required? - no. Do they need to be well informed? - sure. Of course, it really depends on what you mean by "compliance policies" as that is an extremely wide paint brush.

HMDA, Privacy, Compliance Program?

Well, for example, what would your BOD policy on HMDA say? Is it longer than the following two sentences?

The Board intends for the bank to fully comply with all HMDA reporting requirements and meet all other current HMDA regulatory requirements as set forth by our prudential regulatory bodies. The BOD delegates.to Senior Management the responsibility to develop accurate and sufficient written procedures to ensure compliance with all aspects of HMDA by the bank.

That is a policy statement The delegated procedures that would go into much greater detail that are developed by Senior Management are not.

Our "Compliance Manual/Policy" simply states:

It is the policy of The Peoples State Bank to conduct all financial activities in complete compliance with both the letter and spirit of all applicable federal and state banking regulations.

Then it goes on to outline the roles of the BOD, the Compliance Officer and bank personnel. Then a brief description of each regulation monitored. A few examples:

PART 1026 - REGULATION Z. (TRUTH IN LENDING ACT)

http://www.fdic.gov/regulations/laws/rules/6500-3200.html#fdic65001026

PURPOSE. This regulation promotes the informed use of consumer credit by requiring disclosures regarding credit terms, interest rates, and total credit costs.

On October 3, 2015 Reg Z was amended under the Truth in Lending Real Estate Settlement Procedure Disclosure Act (TRID) that incorporated the TIL early and final disclosures with the RESPA GFE and HUD Settlement Statement. These disclosuer are required for all consumer purpose loans secured by real property.

PART 1002 - REGULATION B. (EQUAL CREDIT OPPORTUNITY ACT)
AND FAIR LENDING

http://www.fdic.gov/regulations/laws/rules/6500-200.html

PURPOSE. The purpose of this regulation is to preclude discrimination in the granting of credit based on race, color, religion, national origin, sex, marital status, age, the fact that all or part of applicant's income is derived from public assistance, or the fact that the applicant, in good faith, exercised their rights under the Consumer Credit Protection Act.

PART 339—LOANS IN AREAS HAVING SPECIAL FLOOD HAZARDS

http://www.fdic.gov/regulations/laws/rules/2000-6100.html#fdic2000part339

PURPOSE. The Act establishes the National Flood Insurance Program. It requires that banks ensure that any structure located in a flood hazard area, and used as collateral to secure a loan, is covered by flood insurance. The Act is designed to reduce the potential costs of natural disasters when floods affect populated areas.


TELEPHONE CONSUMER PROTECTION ACT

The Peoples State Bank does not participate in telemarketing activities. Compliance with this act is addressed in the bank’s Do Not Call policy.

FDIC PART 345 - COMMUNITY REINVESTMENT ACT - CRA

http://www.fdic.gov/regulations/laws/rules/2000-6500.html#fdic2000part345

PURPOSE. This regulation establishes the requirement for banks to research, define and meet the financial service needs of their local communities. The CRA officer is responsible for compilation and submission of data and for all other facets of compliance with this regulation.