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Policy & Procedure Management

Policy and procedure management that finds every procedure, job aid and script a rule change touches, drafts each redline, and publishes only what the owner approved and Compliance checked

Every procedure a rule change touches is found and fixed before the rule takes effect.

See the demoBook a demo
See one case, screen by screen ↓
demo17documentsstill quoting the old Regulation CC amounts at the sample credit union, found in one run with the 19 sentences to change
demo7of 17quote an amount the rule sets without ever naming Regulation CC; a search for the citation would miss every one
target1 dayfrom the ripple to every owner's approved redline, not weeks of email
demo612staffasked to read and acknowledge the 17 new versions before they take effect on July 1, 2025
In short

What is Policy & Procedure Management?

Policy & Procedure Management is policy and procedure management for banks and credit unions, done with agents. Every procedure, job aid, form and board policy keeps an owner, a review date and links to the rules it implements. When a rule changes, agents find every document it touches, draft each redline and check the owner's edit against the rule; the owner approves, Compliance checks, and the new version publishes on the effective date for staff to acknowledge.

AI use cases in banking: a buyer's guide to agentic AI for bank and credit union operations →

Updated

The problem

Why policy and procedure management still runs on a shared drive and email

Policy and procedure management at most credit unions and community banks is still a spreadsheet, a shared drive and a long email thread. A compliance analyst reads the Federal Register, NCUA letters and CFPB rules, logs each change with its effective date, and the decision on whether it applies lives in meeting minutes. Then someone searches the drive for the rule's citation, finds the procedures that name it, and emails each owner a list that says "please update".

What the search misses is what goes wrong. The teller quick card and the call script that quote $5,525 without ever naming Regulation CC are never found. An owner edits the wrong Word file, or types the new number wrong, and Compliance reviews some edits with no record of what was checked against what. The intranet page changes on whatever day the edit is done, which is often not the effective date, and early is wrong too. Training sends a "please read" email and nobody knows who read it. At the next exam, the program manager rebuilds the history from email.

typical5amountsin Regulation CC raised for inflation on July 1, 2025 (89 FR 43737): $225 to $275, $450 to $550 and three thresholds from $5,525 to $6,725; every hold procedure, teller quick card and script quoting them had to change on the day
demo47rule changeslogged at the sample credit union between January 1 and May 20, 2025, 19 of them touching at least one document
demo259staffhad still not acknowledged the last policy change ten days before it was due, at the sample credit union
Where the hours go on one rule changeestimated
By hand24 hours
With the solution3 hours
  • Reading the rule and logging its date and numbers2 → 0.3 h
  • Deciding whether it applies, and recording why2 → 0.5 h
  • Searching the drive and intranet for every document it touches6 → 0.5 h
  • Emailing owners and chasing their edits6 → 0.5 h
  • Checking each owner's edit against the rule4 → 1 h
  • Rebuilding the history for the exam or audit4 → 0.3 h

Estimated split of the program's working hours on one rule change that touches procedures, by hand and with the solution, before any owner edits a sentence. By hand, finding the documents and chasing the owners is about two analyst days per change. Not measured.

How it works

How one rule change moves

Eight agents log each rule change, find every document it touches, draft the redlines and check them against the rule; the owner approves, Compliance checks.

What comes in
What starts itAbout 1,240 documents, 96 owners and 40–60 rule changes a year · Federal Register, NCUA, CFPB, board minutes, the procedure library
Agents at work
Watch agentlogs the rule
Then
Impact agentfinds the ripple
Then
Drafting agentwrites redlines
Rule check agentnumber by number
Then
Acknowledgment agentpublishes on the date
Review clock agentowners and reviews
A person decides
The procedure owner approves; a different Compliance Officer checks; the program manager publishesbelow 0.80 confidence, the agent asks a person
What comes out
Every affected document found
Published on the effective date
Examiner history, as of any date
One case, step by step

One Regulation CC change, found in 17 documents and fixed in a day

Norrell Federal Credit Union, a $6.8 billion credit union with 520,000 members, 38 branches, 1,240 procedures and job aids and 96 owners, on Tuesday, May 20, 2025. The Regulation CC funds availability amounts change in 42 days.

  1. 01May 20, 2024

    The rule change logged the morning it was published

    Watch agent · Graham Lindqvist, Compliance Officer

    The Watch agent reads the Federal Register, NCUA letters, CFPB rules and board minutes every morning. At 9:12 AM it logs RC-2024-031 from 89 FR 43737, with the numbers it sets and replaces, its effective date of July 1, 2025, and a proposal that it applies, at confidence 0.98. Graham Lindqvist confirms it the next morning; only Compliance can confirm a change or close one as not applicable, with a reason.

    “Confirmed not applicable by Graham Lindqvist, March 28, 2025” — how a change that does not touch the credit union is closed

  2. 027:02 AM, six weeks out

    Her morning starts with the rule change that matters

    Imogen Castellanos · Policy Program Manager

    Six weeks before the effective date, the lead time set in Settings, the Impact agent re-runs the ripple against the documents as they stand today. Imogen's Today screen says it in one line: one rule change takes effect in 42 days and touches 17 documents. Below it, the five things that need her, among them 23 documents whose owner left on May 9 and 6 overdue reviews.

  3. 03Opening the ripple

    Every document the rule touches, closest first

    Impact agent

    At the top, the rule in one sentence: $225 becomes $275, $450 becomes $550 and $5,525 becomes $6,725, effective July 1, 2025, with its source. Beside it, 17 documents on three rings: 7 cite the rule, 7 quote one of its numbers and 3 depend on a changed document. Each row shows the owner, the sentence that is now wrong with the old number struck and the new one inserted, the agents' confidence and one action: Send to owner.

    “612 staff will acknowledge the new versions before July 1”

  4. 04Ring two

    Job aids that quote the number and never name the rule

    Impact agent

    The Impact agent searched 1,240 documents for 12 CFR 229, then for $225, $450 and $5,525, then followed links to dependent documents. The middle ring holds seven that a search for the citation would miss, among them the Teller Hold Quick Card JA-TLR-07 and the script JA-TLR-11. Three look-alikes are left out with the reason: a $450 daily ATM limit the credit union sets, a $5,525.18 payoff example, and the board policy that quotes no amount.

  5. 059:42 AM, then 10:05 AM

    The owner reads the redline beside the rule and approves

    Renata Okafor · Deposit Operations Manager

    Imogen sends all 17 to their 4 owners in one step, one request each. Renata owns 8. In PRC-DEP-112, Check Deposit Availability Schedule, only the two changed sentences are marked, each with the rule section behind it and why the agents propose it, at confidence 0.99. She can approve as drafted, edit in her own words, or return it with a reason. She approves both as drafted.

  6. 062:50 PM

    Every number in the owner's version checked against the rule

    Rule check agent · Graham Lindqvist

    Once the owners approve, the Rule check agent compares every number in each owner's version with the rule. Sixteen match. One is set aside: in PRC-CC-027, Hold Questions by Phone, the owner typed $6,275 where the rule says $6,725 for the large deposit threshold. Graham approves the 16 that match in one action and returns the one to Owen Achebe with the reason code "Number does not match the rule". The corrected version comes back and he approves it at 3:31 PM.

    “$6,275 does not match: the rule says $6,725 for the large deposit threshold · 12 CFR 229.13(b)”

  7. 073:40 PM

    Scheduled for midnight on the effective date, everywhere at once

    Imogen Castellanos · Policy Program Manager

    Imogen schedules the 17 new versions for 12:00 AM ET on Tuesday, July 1, 2025, in the procedure library, on 11 intranet pages and in course HLD-101 in the learning management system. 612 staff are asked to read and acknowledge them by June 30: 486 tellers and member service representatives, 84 contact center representatives and 42 deposit operations staff. The member disclosure is redrafted too, and because the change speeds up availability, members are told with the June 30 statements, as 12 CFR 229.18(e) allows.

  8. 08At the teller line

    Staff get the answer in force, with its source

    Jada Pruitt · Member Service Representative

    A member deposits a $9,000 payroll check. Jada asks the library how much she can use tomorrow. The answer comes from the published versions in force: the first $225 on the next business day, and a possible large deposit hold on the $3,475 over $5,525, citing JA-TLR-07 and PRC-DEP-114. A note says that from July 1 the amounts become $275 and $6,725. A question about filing a SAR gets no procedure text: it is restricted to the BSA team.

  9. 09For the examiner

    The procedure as it read on any date

    Walter Brandt · Internal Auditor

    Walter picks March 3, 2024 on PRC-DEP-112 and sees version 6, approved by Renata Okafor on September 5, 2023 and checked by Graham Lindqvist, quoting $225 and $450. Below it, the full version history: who changed what, when and why. Version 8 is scheduled; version 7 stays in force until July 1.

  10. 10Closed

    An export pack for the NCUA examiner, built from the trail

    Walter Brandt · Internal Auditor

    Every rule change, redline, approval, check, publication and acknowledgment is on the audit trail with who, when, why and the evidence. Walter builds a pack for the NCUA examiner scoped to RC-2024-031: each version as of each date, the redlines, approvals and checks with reason codes, the schedule and acknowledgments, and the agent versions behind each step. Restricted BSA procedures stay out unless the BSA Officer asks, and the pack is logged with his name.

Who it’s for

Built for everyone who writes, checks, uses or audits a procedure.

The same Regulation CC change at Norrell Federal Credit Union, seen by the five people it passes through: what their day looked like, and what it looks like now.

IC
Imogen CastellanosPolicy Program Manager · sends rule changes to owners, schedules publishing, reports to the Supervisory Committee
Policy Program Manager
Before
Reads the rule, searches the shared drive for its citation, emails a list to owners and chases them for weeks, and still misses the job aid that never names the rule.
Now
Opens one ripple per rule change with every document, sentence and owner on it, sends all of them in one step, and schedules the checked versions for the effective date.
RO
Renata OkaforDeposit Operations Manager · owns 61 deposit procedures, edits and approves their content
Deposit Operations Manager
Before
Gets an email that says "please update", finds the right Word file, and works out which sentences the rule changes.
Now
Reads only the changed sentences, each beside the rule section behind it, and approves, edits in her own words or returns with a reason.
GL
Graham LindqvistCompliance Officer · confirms rule changes, checks every edit, approves setting changes
Compliance Officer
Before
Reviews some of the edits by eye, with no record of what was checked against what.
Now
Sees every number checked against the rule, approves the matching ones in one action and spends his time on the one set aside. He never edits content.
WB
Walter BrandtInternal Auditor · reads every version, approval and acknowledgment, changes nothing
Internal Auditor
Before
Asks what a procedure said on a date and who approved it, and waits while the history is rebuilt from email.
Now
Picks a date and reads the text in force, with its approval and check, and builds the export pack the examiner asks for.
JP
Jada PruittMember Service Representative, Halvern Road · asks the library, acknowledges new versions
Member Service Representative
Before
Answers hold questions from a quick card or an intranet page while the member waits, never sure it matches the version in force.
Now
Asks in plain words and gets the answer from the version in force, with its source and a note when an approved version changes it on a set date.
Built on the engine

8 agents. Each with one job, and hard limits.

Eight agents log each rule change, find every document it touches, draft the redlines and check them against the rule; the owner approves, Compliance checks.

Watch agent

Reads the Federal Register, NCUA letters to credit unions, CFPB rules and guidance and the board's own policy changes every morning, and logs each change with its source, effective date, the numbers it sets and a proposal on whether it applies.

  • Never closes a change as not applicable; Compliance confirms every applicability
  • Every entry links its source
Impact agent

Finds every document a rule change touches: those that cite the rule, those that quote a number it governs, and those that depend on one that does. It ranks them closest first and explains each look-alike it leaves out.

  • Never edits a document
  • Every look-alike carries a reason
  • Below 0.80 confidence it asks a person
Drafting agent

Writes each redline in the document's own words, with the rule passage beside it, and drafts member notices.

  • Never publishes
  • Never changes a sentence the rule does not touch
Rule check agent

Compares every number and citation in the owner's approved version with the rule, and sets aside any mismatch with the rule passage.

  • Exact match only
  • Never approves; a mismatch always goes to a person
Acknowledgment agent

Publishes approved versions at 12:00 AM on the effective date to the procedure library, the intranet and the learning management system at once, tracks who has acknowledged them, and reminds staff and their managers.

  • Publishes only versions the owner approved and Compliance checked
  • Never marks anyone as having read
Review clock agent

Runs the review clock on every document, reminds owners 30, 14 and 7 days before a review is due, and reads departures from the HR directory to propose new owners.

  • Never reassigns on its own
  • Never extends a review
Library answer agent

Answers staff questions only from published versions, cites the passage, and says when an approved version will change the answer on a set date.

  • Never quotes a restricted document to someone without access
  • Below 0.85 confidence it says it is not sure and names the owner
  • Never reads member accounts
Evidence agent

Builds export packs for the NCUA examiner, the state regulator, the Supervisory Committee, internal audit and the BSA Officer: versions as of a date, redlines, approvals, checks, acknowledgments and agent versions.

  • Every pack is logged with who asked for it
  • Restricted procedures only for the BSA Officer
Compliance Officer

Checks every owner's edit against the rule before it can publish. The agents propose; a named person decides.

Ask in plain words

Ask about any rule change, procedure, owner or acknowledgment

Ask the agents in plain words on any ripple or redline, or ask the library from the teller line. Every answer points to the passage it came from.

Which never name the rule?

Seven documents quote a Regulation CC amount without naming the rule: PRC-DEP-121, PRC-DEP-140, PRC-BR-052, JA-TLR-07 (the teller quick card), JA-TLR-11 (the teller script), PRC-CC-027 and PRC-DIG-021. A search for “229” would have missed all seven.

Why is PRC-LN-062 left out?

PRC-LN-062 quotes $5,525.18 as a worked payoff example; it is not a threshold, so no edit. PRC-CARD-019 limits ATM cash to $450 a day; that is a card limit the credit union sets, not the Regulation CC cash withdrawal amount. Add either back if you disagree; it needs a reason.

Can we publish early?

No. Until June 30, 2025 the old amounts still apply. Approved versions wait and publish at 12:00 AM ET on July 1, everywhere at once; staff read them earlier, marked “takes effect July 1”.

When do we file a SAR on a member?

That answer is in a procedure restricted to the BSA team, so I cannot show it here. If something about a member worries you, tell your branch manager or the BSA Officer, and do not mention it to the member.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

Regulatory change management drawn as a rippleOne Regulation CC change at the top, in one sentence with its effective date and source, and beneath it every procedure and job aid that cites the rule, quotes a number it sets or depends on one that does, closest first. Each row shows its owner, the sentence that is now wrong with the agents' redline, and one action: send it to the owner.
The program manager's day, in one lineThe home screen says what needs the policy program manager today: the new ripple, five items that need her, the library in four numbers, rule changes this year and the connected systems.
Rule changes logged, each confirmed by ComplianceThe Watch agent reads the Federal Register, NCUA letters, CFPB rules and board minutes every morning and logs each change with its effective date and the documents it touches. Compliance confirms that it applies, or closes it as not applicable with a reason.
Every value opens its sourceClick the rule's citation and the source passage opens: the Regulation CC funds availability amounts from the Federal Register final rule, each with its section, the amount until June 30, 2025 and the amount from July 1, 2025.
Job aids and scripts that quote the number but never name the ruleThe middle ring of the ripple: seven documents that quote an amount the rule governs without ever naming Regulation CC. A search for the citation would miss every one; the Impact agent finds them by the number.
The owner's redline, beside the ruleThe procedure owner sees the document with only the changed sentences marked, the rule section behind each change, why the agents propose it and their confidence, and decides: approve as drafted, edit and approve, or return with a reason.
Compliance checks every number against the ruleAfter the owners approve, the Rule check agent compares every number in each owner's version with the rule. What matches is approved in one step; a mismatch, here $6,275 for $6,725, is set aside first with the rule passage.
Published at midnight on the effective date, acknowledged firstChecked versions wait for the day the rule takes effect, then go live at the same minute in the procedure library, on the intranet and in the learning management system. The 612 staff who use them are asked to acknowledge them by June 30, and the member notice is timed by the rule.
Staff ask the library and get the answer in forceAt the teller line, a member service representative asks a plain question and gets the answer from the published version in force, with the passage it comes from, and a note when an approved version changes the answer on a set date.
Procedure version control: any procedure as it read on any dateFor an examiner or internal audit: pick a date and see the text in force then, with its owner approval and Compliance check, above the full version history of who changed what, when and why.
A policy review process that keeps every document ownedEvery document keeps an owner and a review date. When the HR directory shows an owner has left, the Review clock agent proposes a new owner for each document with the reason; the program manager prepares the change and each new owner accepts.
The audit trail and an export pack for the examinerEvery rule change, redline, approval, check, publication and acknowledgment is recorded with who, when, why and the evidence. An export pack for the NCUA examiner, the state regulator, the Supervisory Committee, internal audit or the BSA Officer is built from it and logged.
Roles with separation of dutiesSettings start with who may do what: the owner writes, Compliance checks, the program manager publishes. Nobody approves and checks the same version, the auditor reads everything and changes nothing, and the administrator proposes settings that Compliance approves.
Governance

Built for the examiner: every version owned, approved, checked and on the record.

Separation of duties on every versionThe procedure owner writes and approves the content, Compliance checks it against the rule, and the program manager publishes. Nobody does two of these for the same version, the publisher approves no content, and the internal auditor reads everything and changes nothing.
Maker and checker on every changeEvery new, changed or retired version takes the owner's approval and a Compliance check before it can publish. A member notice is prepared by the owner and approved by Compliance, a reassignment is prepared by the program manager and accepted by the new owner, and a setting change is proposed by the administrator and approved by Compliance.
Every value citedEvery amount, date and agent statement carries its source: a click opens the rule's table of amounts, the Federal Register entry, the HR directory record or the passage of the procedure it came from.
Agents versioned, overrides with a reasonEach agent runs at a pinned version with its model, confidence threshold and golden-set score, approved by the Compliance Officer. Below its threshold an agent asks a person. Returning a redline, closing a rule change or adding a look-alike back takes a reason code, kept on the trail.
Restricted where it must beBSA procedures are visible only to the BSA team. The library never quotes them to staff without access, and no member-facing text is drafted from them, so a SAR is never revealed. Access follows roles from the HR directory, and member data in procedure examples is redacted on save.
A history examiners can exportWho, what, when, why and the evidence for every rule change, redline, approval, check, publication and acknowledgment. Every version is kept 7 years after it is replaced, BSA procedures at least 5, and export packs for the NCUA examiner, the state regulator, the Supervisory Committee, internal audit and the BSA Officer are logged with who asked.
Configuration

Your review cycles, your sources, your approvers

The credit union's procedure program ships as settings. The administrator proposes a change, and the Compliance Officer approves it before it takes effect.

SettingDefaultChoose from
Version approvalsOwner → Compliance → program manager publishesNobody approves and checks the same version; a member notice is prepared by the owner and approved by Compliance
Review cyclesEvery 12 monthsRegulatory procedures and job aids every 12 months; operational procedures every 24 months
Review reminders30 · 14 · 7 daysBefore the due date; escalation to the department head 7 days overdue
Sources the Watch agent readsFederal Register, NCUA, CFPB, board minutesFederal Register daily at 9:00 AM ET; board and committee minutes when filed
Ripple re-run6 weeksBefore the effective date, against the documents as they stand that day
Publish time12:00 AM ETOn the effective date, never before; acknowledgment due the day before, with reminders 10 and 3 days ahead, then the manager
Agent confidenceImpact 0.80 · Library answer 0.85Rule check exact match; below the threshold a person decides
Records kept7 yearsAfter a version is replaced; BSA procedures at least 5 years; 38 BSA procedures restricted to the BSA team
Connections

Works with the systems your procedures already live in

Procedure libraryprocedures, job aids, forms and board policies; reads them and publishes new versions, keeping the old ones as history
Learning management systemcourses such as HLD-101, assignments and staff acknowledgments
Intranetthe pages that carry procedures to staff, published at the same minute as the library
HR directorypeople, roles and departures, nightly; who may see what
Regulatory change feedsthe Federal Register, NCUA letters to credit unions and CFPB rules and guidance
Board and committee minutesthe credit union's own policy changes, with the board date
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
100%
of the documents that quote a changed rule's numbers found, including job aids that never name it
17 of 17 in the demo
3 never name the rule
target
1day
from the ripple to every owner's approved redline, not weeks of email
Email and spreadsheetsweeks
With agents≈ 1 day
target
0
versions published without the owner's approval and a Compliance check
One person edits and postsOwner and Compliance

“demo” = seen in the working solution, on its sample procedures, rule changes and staff · “target” = the design goal, measured in the live solution · “estimated” = our estimate of where the program's hours go on one rule change · “typical” = published figures (Regulation CC threshold adjustments, 89 FR 43737, Federal Reserve Board and CFPB, published May 20, 2024, effective July 1, 2025; 12 CFR 229.18(e) on notice of a change in availability policy; 31 CFR 1010.430 on keeping BSA records five years). People, the credit union, its branches and the document numbers named on this page are fictional — characters and sample data in the working solution.

Questions

What compliance teams ask about policy and procedure management.

What is policy and procedure management?

Policy & Procedure Management is policy and procedure management for banks and credit unions, done with agents. Every procedure, job aid, form and board policy keeps an owner, a review date and links to the rules it implements. When a rule changes, agents find every document it touches, draft each redline and check the owner's edit against the rule; the owner approves, Compliance checks, and the new version publishes on the effective date for staff to acknowledge.

How does regulatory change management reach the procedures a rule touches?

The Watch agent logs each change from the Federal Register, NCUA, the CFPB and board minutes with its effective date and the numbers it sets, and Compliance confirms whether it applies. The Impact agent then draws the ripple: documents that cite the rule, documents that quote a number it governs, and documents that depend on one of those, closest first. It re-runs six weeks before the effective date, so a job aid added since the first run is caught.

How does it find job aids and scripts that never name the rule?

It searches by the numbers the rule sets, not only by its name. In the sample case, seven of the 17 documents quote $225, $450 or $5,525 without naming Regulation CC, among them a teller quick card and a teller script. Look-alikes, such as a $450 daily ATM limit the credit union sets, are left out with the reason, and the program manager can add one back with a reason code.

What happens if an owner types the wrong number?

The Rule check agent compares every number in the owner's approved version with the rule before Compliance signs. In the sample case it set aside $6,275 where the rule says $6,725, with the rule passage. Compliance approved the 16 matching documents in one action and returned that one with the reason code "Number does not match the rule".

Does it track policy attestation by staff?

Yes. The staff who use a document are asked to read and acknowledge each new version before it takes effect, marked with the date it does. The Acknowledgment agent reminds them 10 and 3 days before the due date, then their manager, and it never marks anyone as having read. Each acknowledgment records the name, time and version.

Can an examiner see a procedure as it read on a given date?

Yes. Pick a date on any document and the text in force that day appears, with who approved it and who checked it, above the full version history. Every version is kept 7 years after it is replaced, BSA procedures at least 5, and an export pack for the NCUA examiner, the state regulator, the Supervisory Committee, internal audit or the BSA Officer is built from the trail and logged.

Do people stay in control?

Yes. The agents find, draft, check and remind; they never publish, approve, check, reassign, close a rule change or mark anyone as having read. The owner approves the content, Compliance checks it, and the program manager publishes, and nobody does two of these for the same version. Any agent proposal can be overridden with a reason code.

How does it go live at our credit union or bank?

The Agentic Solution Engine builds and deploys it from your requirements, your documents and your rules: your procedure library, review cycles, roles, approvers, reason codes and restricted documents, connected to your learning management system, intranet, HR directory and regulatory change feeds. It goes live once every quality gate has passed.

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We'll run Policy & Procedure Management on a sample of your own procedures and job aids, against a rule change you have already handled.

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