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#39332 - 10/29/02 12:11 PM Reg CC policy
DebbieC Offline
Member
Joined: Jul 2001
Posts: 66
Owensboro, KY USA
I have always been under the impression that Reg CC policy needs board approval, but I cannot find it anywhere in the regulation or the commentary. Am I overlooking it, or is it silent on approval of the policy?

Thanks.

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Operations Compliance
#39333 - 10/29/02 01:14 PM Re: Reg CC policy
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,748
On the Net
I don't believe it is specifically stated in "CC" as you may see it in BSA or the CIP proposal. But generally speaking the bank's board is the body that approves policy. Senior management approves procedures.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#39334 - 10/29/02 02:48 PM Re: Reg CC policy
ahou Offline
Power Poster
ahou
Joined: Aug 2002
Posts: 3,094
There is no requirement in Reg CC to have the board approve the Reg CC policy. All the institutions I have worked for sent policies to the Board when implemented, and again when any changes were made. The institution I work for now, sends all major policies to the Board annually. This ensures that the policies are being reviewed for any necessary changes. Changes are highlighted within the document to expedite review. [probably more than you wanted to know!]
_________________________
Opinions are my own and not of my employer.

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