If you want sample policies for customization, there is no question that you can find them. Web search “sample bank or credit union policies” and you’ll see a plethora of sources for canned policies. Some are even free. But, then again, sometimes you get what you pay for, and sometimes, free can end up being very costly. The key question is whether you have ACCESS to quality policies.
What constitutes a quality policy? Think of a mariner lighthouse. It serves as both guide and warning voice to those seeking passage on the often-rough seas. If the lighthouse keeper does not maintain the light diligently, it may become weak and invisible. If followed completely, however, those who seek its high and colorful beacon may find themselves in clear danger. It must be used as a guide to steer the mariners away from trouble yet in the direction they should go.
Without question, you want to have policies that satisfy examiners. They are most interested in the safe passage of those under their care. You also want policies that guide your financial institution. With those two baseline objectives, here are the logical sources of a quality policy:
Policies should have a strong connection to the regulatory agencies. After all, regulatory agencies have a strong connection to rules & regulations, statements of policy, etc. High quality policies echo regulatory concerns and state your goals within the framework of those concerns. As such, a quality policy has heavy emphasis on regulatory elements. Whatever policy you select as your starting point, make sure that it has a connections to the latest regulatory guidance. This is where dynamic policy sources are critical. Your policy will undoubtedly require frequent updates. So, finding a policy is only part of the equation. If you copy a policy from various sources, you’ll still need to make sure your policy is updated to reflect regulatory changes.
Second, you want the policy to fit your institution. Achieving the balancing act of providing enough information to guide users without overloading them is always a challenge. You know your institution and know the level of guidance needed within a policy. A hallmark of a strong quality policy is that it distinguishes between policy elements vs. procedural requirements. This difference requires guiding the policy towards those elements and then segregating the details of process into your procedural guides.
As you draw on the various sources for policies, remember that the creation and management of those policies is both an art and a science. When properly designed and managed, your policies will serve as beacons for your institution.
