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#545136 - 05/09/06 03:08 PM Program verses Policy
BankerKB Offline
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BankerKB
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Posts: 288
What is the difference between a Program verses a Policy?
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#545137 - 05/09/06 03:18 PM Re: Program verses Policy
RR Joker Offline
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The Swamp
Really, to me...terminology. Our GLBA, for instance, is our "Information Security Program" and encompasses our Techology Info Security, Privacy and GLBA Info Security Policies.
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#545138 - 05/09/06 04:04 PM Re: Program verses Policy
Elwood P. Dowd Offline
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Next to Harvey
I'm confident, perhaps overly confident, that I can tell the difference between a policy and a procedure. However, I'm confused by the term "program" as well. My opinion, similar to Joker's, is that the bank's "program" is everything it does, i.e. the all encompassing label placed on policies and procedures aimed at compliance with a particular requirement.

Now, does anyone know what "process" means? The BSA/AML manual has an oblique reference to a bank's adherence to its "processes."

Writing "policy" and "procedure" over and over again may get tiresome for the regulators, but using fuzzy terms as synonyms just confuses the troops.
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#545139 - 05/09/06 05:34 PM Re: Program verses Policy
RR Joker Offline
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Ken..process goes hand in hand with 'procedures'. What is the bank's "processes and procedures"...listed separately but as far as I'm concerned...means the exact same thing!

I can say the FED...LOVES our GLBA PROGRAM! So, I'm leaving it the HECK alone!!!!!
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#545140 - 05/09/06 09:17 PM Re: Program verses Policy
Richard Insley Offline
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Richard Insley
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Toano, VA
The language of our industry is becoming duct tape. "Policy," "procedure," "process," and "program" now mean the same thing; "loan" and "line" are used interchangeably; "the T-bill rate" covers any index that's even remotely related to a U.S. Treasury security; singular personal pronouns have been replaced by the always-PC "their"; and "compliance" is used as any part of speech. Pogo got it right--and we shouldn't be surprized when employees can't comprehend those policy/procedure/program/processes.
Last edited by Ken_Pegasus; 05/10/06 10:29 AM.
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#545141 - 05/09/06 11:55 PM Re: Program verses Policy
Kathleen O. Blanchard Offline

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In a program our friends are usually looking for your overall documentation that spells out how you manage a "topic". The bigger you are the more formal they want the program to be. It might be just gathering together the related policies and procedures on information security (IT info security, risk assessments, clean desk policy, privacy disclosures, etc. and handing those to the regulator. Or, as you get larger, they sometimes like to see that all formally gathered together in a document that might cross reference policies that are voluminous (like all of the IT policies) but contains the others and has a table of contents, etc. They see that kind of thing at the big banks and like it 'cause it makes their life easier. Whether it is in a binder with a TOC or not, how you manage the "topic" from soup to nuts is viewed as your program.
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#545142 - 05/10/06 10:32 AM Re: Program verses Policy
Elwood P. Dowd Offline
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Elwood P. Dowd
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Next to Harvey
Quote:

The language of our industry is becoming duct tape.



So, for a country boy, it's the equivalent of Scotch tape and binder twine? Classic. Absolutely classic.
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#545143 - 05/10/06 06:13 PM Re: Program verses Policy
RR Joker Offline
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RR Joker
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The Swamp
Quote:

In a program our friends are usually looking for your overall documentation that spells out how you manage a "topic". The bigger you are the more formal they want the program to be. It might be just gathering together the related policies and procedures on information security (IT info security, risk assessments, clean desk policy, privacy disclosures, etc. and handing those to the regulator. Or, as you get larger, they sometimes like to see that all formally gathered together in a document that might cross reference policies that are voluminous (like all of the IT policies) but contains the others and has a table of contents, etc. They see that kind of thing at the big banks and like it 'cause it makes their life easier. Whether it is in a binder with a TOC or not, how you manage the "topic" from soup to nuts is viewed as your program.



Ours would pretty much mirror the larger bank document KB describes...clickable TOC and all.
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#545144 - 05/10/06 09:41 PM Re: Program verses Policy
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Yep! They really want to see that the bank has connected the dots..done the risk assessments and impact assessments, looked at all of the policies and procedures as a cohesive unit and paid attention to how it all works together. Are things defined the same way across the board? Has everything been covered? Is information cross-referenced where necessary? Have you identified gaps and developed action plans to address?

They want to be sure you have your arms around the topic.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
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