Policy management: Meet FDIC expectations with smart use of your resources

Today, a regulator is at your organization and is not happy. Their examination reveals a significant number of customer complaints regarding overdraft fees.

You quickly provide copies of your board-approved policies covering insufficient funds fees and customer complaints.

Undeterred, the regulator asks:

• When were the policies last updated?
• What changed?
• Where can employees find the latest version?
• How do you know employees understood the policy change?
• How were the current policies communicated and implemented?
• Are the procedures, resources and incentives that encourage compliant behavior?

Unfortunately, if you are like most financial services organizations the answers to those questions are less than what the regulators expect.

According to the FDIC, policies is the leading category of “Matters Requiring Board Attention” or MRBAs, flagged by the regulator. The expectation today is that your policy management program is not limited to policies and acknowledgements. In fact, policies and acknowledgements are just part of an overall policy management program that communicates organizational leadership expectations and encourages compliant behavior.

Policy management programs should include:

• An auditable workflow process detailing policy changes, reviews, and approvals;
• A documented method of tracking policy-related communications, acknowledgements, and comprehension;
• A centralized repository for the current version of all policies as well as related procedures, checklists, and best-practices resources.

It’s time for management software

For many organizations still utilizing a series of standard business software applications — like Word, Excel, email, and an intranet — to manage an ever-growing list of policies and procedures, this expectation from regulators can seem unrealistic. They simply do not have the resources needed to meet expectations.

Fortunately, today there are affordable policy management software solutions that can help improve and automate these processes.

What to look for in a policy management software

Scheduling functionality

Specifically look for user-experience features that keep everyone focused on staying on schedule with updates and acknowledgements, including:

• Target completion dates
• Compliance professional and manager dashboards
• Report subscriptions
• Reminder emails
• User dashboards
• Audit reports

Communication tools

Communication tools allow compliance professionals to ensure everyone in their organization sees, understands, and can quickly reference the policities and procedures needed to do their jobs effectively. Look for:

• A centralized repository
• Full text search
• Bookmarking
• Distribution
• Acknowledgement tracking
• Quizzes

Administrative features

Administrative features that help save your time and increase the effectiveness of your poicy management program include:

• Bulk import of existing policy documents and users
• Industry-specific table of contents
• A human resources information system (HRIS) data exchange
• Configurable and reusable workflows
• Single sign-on (SSO)
• Onboarding support, training and help resources

Christopher Boersma, CRCM, CAMS, CISA is a product manager at BAI.

An expanded version of this article was initially published by BAI’s Learning and Development team.