Has anyone ever heard of management dictating BSA policy? I have a situation where management, who's not happy with the Board approved policy written by the Officer, is strong-arming the BSA Officer to make exceptions to policy. IMO, this is a larger issue of independence. Any thoughts on how one should proceed in this situation?

Thanks in advance!

If you do not, find someone that reports directly to the board of directors, like your head of internal audit and get them involved. Depending on the exceptions to policy that management is strong arming you into making, it might also trigger a SAR filing.