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General Information:

Written and observed policies and procedures are the foundation to a solid compliance management system that gives employees a clear roadmap to compliance and in meeting service standards. The Board of Directors demonstrate responsible leadership and governance by approving policies of the credit union.

The policies in this RADD LLC. Sample Policies are intended to provide a framework. You should build on the policy template by Incorporating your institution’s specifications. A generic policy will not provide sufficient guidance to employees.

RADD LLC. does not provide legal opinions or legal advice. The templates here should not be relied upon as a substitute for professional services. RADD LLC. does not warranty these templates and will not be liable for any direct, indirect, or consequential damages resulting from or emerging from the use of any of the policies herein.

An effective policy should not restate a law or regulation. The policy should capture the specific position or requirements of your credit union. Contact us if you are interested in our assistance in customizing policies with a greater deeper scope to help you meet regulatory requirements.

Your credit union’s policy should show your position with respect to the key points of the regulation, statute, law, guidance, etc. Examiners have come to expect the following policy components:

• Enforcement and Oversight: State who is responsible for the ensuring the policy is compliant and reporting to the Board of Directors.
• Audit and Monitoring: State who is responsible for auditing and/or monitoring the credit union’s compliance with the policy and reporting the results to the Board of Directors. You must show that you are in compliance with your policy.
• Training: State who is responsible for ensuring training on the policy is provided to new and existing employees and the frequency of training.
• Record Retention: State how long the supporting documents evidencing compliance be retained.

As a result, RADD LLC. has incorporated these four components in each of our policies.

Because the Board of Directors must approve all policies, we recommend that you maintain policies and procedures separately since procedures are often revised. In maintaining the procedures separately, the Board of Directors will only need to approve changes to the policy.Through the approved policy, the Board of Directors tells the credit union how to comply; management needs to create the procedures to execute. Some regulations require an entire program (e.g., BSA, Identity Theft, CIP), which includes policy and procedures. In these instances, the program (policy and procedures) must be approved by the Board of Directors. For higher risk areas policies should state what is and is not acceptable risk for the credit union.

The RADD LLC. Sample Policies focus on key consumer compliance and BSA-AML regulations. They are dynamic documents that will be updated as regulations are amended. We utilized several resources in creating the templates, including the regulations, statutes, laws, regulatory/agency guidance, and our professional work experience. The templates are not intended to replace reading or referencing the actual laws or regulations. The templates are guides as to the most common compliance matters that credit unions face. Be sure to carefully review the templates and tailor each policy to your credit union’ specific policy statements.

Thank you for selecting RADD LLC. to assist you with your compliance needs.

Disclaimer: While the publisher and author have used reasonable efforts in preparing the policy samples, the publisher and author provide the templates in “as-is” condition and without warranty or condition of any kind, including specifically, but without limitation, any warranty with respect to the accuracy or completeness of the contents of the sample policies. No warranty of the sample policies may be created or extended by representatives of RADD LLC. The templates contained herein may not apply or be suitable for your situation. You should consult with a professional where appropriate. The accuracy and completeness of the information provided herein are not guaranteed or warranted to produce any particular results and are not suitable for every credit union. By providing information or links to other websites, the publisher and author do not guarantee, approve or endorse the information or products available at any linked websites or mentioned companies, or individuals, nor does a link express any association with or endorsement by the publisher or author. This publication is created to give information with regard to the subject matter covered. It is licensed with the understanding that neither the publisher nor author is engaged in rendering legal, accounting or other professional service. If legal advice or other expert assistance is required, the services of a qualified professional should be sought. Neither the publisher nor author shall be liable for any loss or loss of profit or any other commercial damages, including but not limited to special, incidental, consequential, or other damages. THE PUBLISHER AND THE AUTHOR EXPRESSLY DISCLAIM ANY AND ALL IMPLIED WARRANTIES OR CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND/OR NON-INFRINGEMENT.

Please do not provide or attach any document containing any member non-public personal information, including identifiable financial information and any list or grouping of members derived from personally identifiable financial information, in violation of the California Consumer Privacy Act Senate Bill 1121- SB 1121 of and Gramm-Leach-Bliley Act 15 USC Section 6801 et. Seq. Neither RADD LLC, Inc. nor its employees/consultants shall be liable for any loss or loss of profit or any other damages, including but not limited to special, incidental, consequential, or other damages related to the provision of nonpublic personal information. RADD LLC, Inc. does not provide legal opinions or legal advice. As such, the services provided by RADD LLC, Inc. should not be construed as legal services, legal advice, or in any way establish an attorney-client relationship.