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Compliance Procedures

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Question: 
Our regulators (the OCC) have suggested that we purchase Compliance procedures. I am looking for a good source to obtain those from. Can you offer any suggestions?
Answer: 

Answer by Ken Golliher:I am completely mystified by the suggestion that procedures can be purchased. Generic policies, okay, but not procedures. Policies focus on "why" and should be broad in their pronouncements. Procedures deal with who, what, when, where and how. In contrast, they are very, very specific. From one bank to another, procedures are affected by an almost infinite number of variables. Procedures are like fingerprints, they have common features, but in toto they are unique to a particular bank.

Answer: 

Answer by John Burnett:I would encourage you to obtain policy templates (there are a number available in the BOL Banker Store), but I feel I must second Ken's suggestion that procedures are by definition "home grown." They reflect the "how, we, and it" for each bank, and implement policies. Every bank's procedures will be unique. They will reflect the people you have, the products you offer, the demographics of your market area, the mix of your customers, the makeup of your balance sheet, and a host of other things that make your bank, well, your bank.

First published on BankersOnline.com 8/21/06

First published on 08/21/2006

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