I am curious what other banks not included under the Sarbanes-Oxley requirements are doing with regard to having formal fraud or whistle blower policies. I think it is a good idea for smaller banks too, because since there are not normally as many levels of scrutiny and smaller departments tend to develop more of a trusting attitude ("they would never do anything like that," "I have worked with them for 20 years," "they have been good employees forever," etc.) there is room for the obvious. What do you guys do (under $500,000 in assets)?

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Thanks Kari-I had checked those out before and didn't see much of a response but did find an actual e-mail address to request a copy of one.