I am really unsure why a trust department's policies and procedures would ever be incorporated into the general bank's policies and procedures. They are really two totally different animals.
Shifting Reg Oversight From FRB to FDIC
Our BHC previously held an FDIC, state-chartered bank and a trust company as separate entities. The trust company is now in the process of becoming a wholly-owned subsidiary of the bank. The long-time personnel of the trust company will continue to operate the trust company as it always has. Since the regulatory oversight for the trust company will now shift from the FRB to the FDIC, is it acceptable for the trust company to maintain its existing policies and procedures separate from those of the bank?
First published on 03/24/2014