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#1616404 - 10/17/11 04:09 PM required policies
Anonymous
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Is it acceptable for the bank's policy to state that the bank will comply with the requirements of the regulation and not be more specific than that? Example, It is the bank's polilcy to comply with all requirements of the appraisal rules. We do have procedures, but the procedures are general too.

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#1616419 - 10/17/11 04:22 PM Re: required policies Anonymous
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Policies are general. Procedures are very specific. In general, neither is required to make reference to specific elements of a regulation. It would only be appropriate to refer to a regulatory citation in a procedure if it would add clarity to the instruction the employee is being given. Most of the time, it would be a source of confusion, not clarity.
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#1616482 - 10/17/11 06:27 PM Re: required policies Elwood P. Dowd
Anonymous
Unregistered

Ken, are you saying that it is ok to have our entire appraisal policy be one sentence, "It is the bank's policy to comply with all requirements of the appraisal rules." I understand the part about the policy being general. But, it just seems too general to me. I'm at a new bank, and what I have stated is the entire policy.

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#1616562 - 10/17/11 08:18 PM Re: required policies Anonymous
P*Q Offline

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P*Q
Joined: May 2001
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Policy is one thing but having been stung during past exams for not having detailed enough procedures, I'd recommend that if you have a "light" policy, you back it up with detailed procedures to ensure compliance. Just my opinion.

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