We have so many policies it makes my head spin!

My question is when do you get a change in the policy approved by the BOD? Take FACT Act and the new accuracy and integrity rules. Would you submit the new section to the BOD now? (obvioulsy I'm late on this one!) We have an annual meeting at the end of the year where all of the policies are approved but I don't know if the regulators want them approved by the compliance deadline dates.

With so many changes to the different regs, I feel like I'll be in the boardroom once a month to get new policies approved!!!

Thanks for any advice.

Your policies should be approved at the time they are changed. Theoretically, they are presented to the board, discussed, and then approved after thoughtful consideration.

Reality is closer to the situation where you could get the board to vote on a ham sandwich and they would do it.

You could also separate out what is truly procedures. When allowed by regulation (which is most of the time) have a policy that is at a higher level and then a non-board approved procedure that is the day to day "how to". You explain to the board the process that carries out the policy to demonstrate compliance to them, but do not have them approve the procedure. Day to day management is delegated to bank management.

Using that type of policy and procedure process, you avoid having to go to the board for changes in a vendor/process/approval level, etc. when the actual policy has not changed.

Another thing you can do to keep it less burdensome is rather than approve all policies annually, the ones that don't have any changes you can list on a spreadsheet, noting no changes, and ratify those policies annually without having to present the actual policy.

Obviously, all policies should be available upon request.

I also agree with Kaybee except for when a regulation specifically requires the procedures to be approved.

SO true!

Any one have a list of what Policies are actually required?

For instance I read a thread the other day stating that a bank isn't required to have one regarding SCRA. My instition seems to have policies for EVERYTHING - talk about spinning heads! They review/revise on an revolving annual bases, so every month something is being placed before the board and prior to that the compliance committee.

We have started working on separating procedure out, for reasons mentioned above.

Thanks for letting me ramble on... back to the original question anyone have a list of required policy, and would you be willing to share.

Thanks.