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The Financial Institutions Bureau is developing a program
that will emphasize compliance with policies formally adopted
by bank Boards of Directors. Rather than instructing bank examiners
to criticize practices that are deemed improper for banks based
on generally accepted industry standards, the Bureau will be
placing more reliance in bringing to the attention of Boards
of Directors practices which do not conform to their own established
policies. Before this program can be put into effect, it is
necessary that bank management, bank directors and bank examiners
become aware of this new emphasis on examinations.
To begin implementation of this program the Bureau will, over
the next eighteen months, periodically issue Bank Bulletins,
each dealing with a specific policy area. (Bank Bulletin No.
8, dated February 3, 1975, dealing with "Short-term Money Market
Funds" required the adoption of written Board policy.)
Each bulletin will require a written policy on a particular
policy area. Each bulletin will also include a listing of key
issues we feel the Board should address in arriving at its overall
written policy on the subject matter of the bulletin.
These policies, as developed, should be maintained in a policy
book of the Board that will be available for examiner reference
and use during the course of an examination. A copy of all other
written policies developed and adopted by the Board should also
be maintained in this policy book.
Policy areas we intend to emphasize during the next year are:
- Lending
- Investments
- Conflict of interest
- Insurance
- Board
- Audit program
- Earnings and capital
Bankers are encouraged to develop such policies according to the
particular needs of their institution and their own management
philosophy.
| Signed: |
Richard J. Francis, Commissioner |
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Gifford Knudsen, Director, Bank & Trust Division |
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| Dated: |
November 7, 1977 |
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