Answer:
I absolutely agree with removing procedures from the policy. In fact, we have written an article on this topic, called "Policy, Procedures and Processes". You can find it at our website.
First published on BankersOnline.com 5/04/09
Stripping Down a Massive BSA Policy/Program
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Question:
The size of banks BSA Programs has increased to 50 pages or more. I would like to strip the BSA Policies/Program of specific procedures. The BSA Program would refer to a procedures manual with appropriate ID. This way, anytime procedures needed to respond to changes they would not need board approval. The question is: can I have a separate BSA/Policies/Program, which references a separate procedures manual?
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