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Bank Protection Act Requirements

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Question: 
Is it a requirement of the Bank Protection Act to annually receive board approval for the Reporting of Criminal Acts Policy?
Answer: 

Since it's not a requirement of the Bank Protection Act to even have a "Reporting of Criminal Acts" policy, I can't imagine that it would be a requirement of that act to have it approved, but just because something is or is not required by a particular act isn't really the point. Why do you have this policy? If you have this policy for a reason, does that reason still exist? If that reason still exists, does the policy need to be updated and refreshed? Does the policy itself or the bank's overall policy process require annual re-approval of board-level policies? All of these would be relevant factors to consider. As an aside, this policy maybe could be combined with the bank's SAR Reporting Process which should be documented in the bank's BSA/AML Program which is required to be board approved.

First published on BankersOnline.com 11/15/10

First published on 11/15/2010

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