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Developing a 5th Pillar Policy

Question: 
It appears we are going to be starting from scratch in developing the new CDD 5th Pillar language that must be added to our policy. Any thoughts on how to proceed?
Answer: 

Much of the language you will need to satisfy the new 5th Pillar requirements in already in the Internal Controls section of your current BSA Policy and will simply be moved to this new fifth section of your policy.
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Learn more about Don Blaine’s webinar
Why Did CDD Deserve to be the 5th Pillar Rather Than CIP?

First published on 06/11/2017

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