I'm increasingly sensitive to the fact that MSB's service millions of customers that banks do not want. In many cases, I think closing their accounts across the board is a mistake. Yet, if a bank concludes that it cannot mainain the relationship profitably, that is the only reasonable choice.
Three fourths of maintaining the relationship profitably is adjusting fee schedules to reflect the necessary level of administration and monitoring as well as the regulatory risk involved. However, the other fourth is developing the expertise necessary to review the MSB's policies and procedures as well as to be able to develop policies and procedures on the part of the bank. It's that last fourth, the expertise, that is the most critical.
A borrowed policy from another bank, even a good one, is more likely to get you skewered than protected.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.