I am in the process of updating my company's CIP policy and procedures. We have never before had a unified CIP policy and procedure in one document, even though it is required by law.

My question is this: How detailed is your policy and procedure together? Do regulators prefer the CIP policies for each business unit incorporated into the BSA/AML policies for that particular business unitor do they want one CIP document incorporating CIP policies for all business units into one document?

I'm doing the latter of the two, and I'd like to hear what other institutions have done in writing their CIP policy policy and procedure. Thanks in advance!

BW

Our policy states what we will do to comply with the regulation. Our procedure states how we will comply and it incorporates all business lines. This way if you have to update or change your policy/procedures you can do it from one spot.

Jennifer

Based on conversations with our regulators, they don't care as long as the CIP policies and procedures are specific to each situation. We have a general CIP policy and procedures in our BSA Manual; however, these have been modified in the manuals for several of our business lines. Our general policy incorporates department-specific procedures by reference.

Thanks for the responses - BrendaC, were a pretty vanilla shop, retail banking and lending; nothing too specialized. Our retail area only offers products to customers, and most of our loans go to deposit customers. Although lending has sub groups like consumer, mortgage and commercial, they all get their customers essentially the same way.

I put our policy together with this in mind and only broke out our procedures by lending and deposits. I discuss separate products, but the CIP process is essentially the same.

Thanks again!