We are not aware of any specific rules that require a bank’s board of directors to pre-approve the bank’s policies and procedures with respect to closing deposit accounts. However, since directors generally are charged with the duty to establish and monitor a bank’s policies, we recommend ensuring that your board is made aware of any material changes made to the bank’s account closing policies, even if after the fact.
In addition to the language contained in our deposit account agreement, should a bank’s deposit account closing standards be approved by the board of directors? If so, how often should this be approved?
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