Using Our Products: We Make Your Job Easier
BankPolicies.com highly recommends that clients use the following guidelines when using our products:
Our products are simple Microsoft Word documents that provide a convenient starting point to implement an effective policy, procedure, job description or form solution. You should never implement our products in their initial form simply by adding your organization's name or logo. In any event, you must customize our products to adapt to your organization's specific requirements. To help achieve this goal, we recommend that you:
- Save the original document on your computer or network for your records;
- Make a copy of the original document that you will use as a draft; and
- Add, change or delete any of the contents as you deem appropriate.
Products purchased from BankPolicies.com may not be used (not copied, resold, performed, distributed, rented, sublicensed, altered, stored for subsequent use, etc. in whole or in part, in any manner which would constitute a violation under the Copyright Act) without BankPolicies.com's express prior written consent.
Using our product as a starting point, take into consideration what you have learned from the interview process and create a drafted document. Your draft, along with our original product, should be submitted to your management committee or others who are involved in the creation process for review and discussion. The draft should be reviewed and any changes made before a final version is submitted for approval to senior management and/or the board of directors.
Interview people within your organization, ask questions, find the facts, and create a document that mirrors your operations and philosophies. It is best to create a policy that contains subsequent procedures that support its directives, rather than pointing to another document or binder. Regulators and independent auditors like to see one simple reference source for your institution's policies and procedures.
Each document in your policy manual should have an identical layout. It is best to make one person accountable for your policy manual to ensure consistency and content, yet development should be supervised by a management committee. Use the same format (e.g., font size, title location, table of contents, date area, header, footer, page numbers, etc.) for uniformity. The use of a numbering and volume system (i.e., documents indexed based upon the subject matter, such as Administration - 100 Series, Compliance - 200 Series, Lending - 300 Series, Operations - 400 Series, etc.) will also promote ease of use and reference.
Write only what needs to be written in a language that everyone understands. Be specific, and keep to the point. Try to write the policy like a book, from beginning to end, achieving an easy flow of understanding for each topic. Begin with a major topic and provide the required detail for each.
It is important to be specific when assigning responsibility and accountability to ensure your staff clearly understands assigned responsibilities. It is best to not list specific employee names, but rather titles or branch or department names (e.g., Chief Financial Officer, Main Office, Loan Servicing Department, loan officer, teller, etc.) when applicable.
Exhibits are various pieces of support documentation used as attachments to a particular policy or procedure. As an example, forms, reports, diagrams, work tickets, contracts, and other materials may be used. It is best to use completed examples, using fictitious names, addresses, account numbers or dollar amounts to help in the overall understanding of intended use.
The best policy is one that is reviewed on a periodic basis and amended as needed to ensure compliance with industry best practices issued by the Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve, Office of the Comptroller of the Currency (OCC), or other federal regulatory bodies that may apply to your organization. Board approved policies generally are to be reapproved on an annual basis. Procedures, more often than policies, require periodic maintenance based upon the recommendations of personnel using them on a daily basis. Careful consideration must be applied to edits, updates or modifications to ensure that proper control is maintained. The final authority for the approval of revisions or modifications lies with senior management and/or your board of directors. Providing bolded, underlined, notated or strike through marks helps everyone involved in the revision and approval process.
Ensure your policy manual is easily accessible to designated personnel via tracked distribution in hard copy form or electronically on your computer network. If distributing in hard copy form, attach a cover "circular" that briefly mentions the new or updated policy. Make the recipient accountable for ensuring the new or revised policy is promptly placed in his or her manual by requesting a signed acknowledgment. If distributing electronically, your e-mail will suffice as a cover "circular" and a return receipt reply will suffice as the acknowledgement.
A new or revised policy or procedure may require staff training. This is an essential part of the education process. In some instances (usually dealing with regulatory issues), management must not only conduct training with staff but also provide evidence of that training. Documenting, recording and controlling training records are critical to ensure the success of compliance and independent audits.
Please contact us if you have any questions.
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