Bank Document Imaging Policy

“Do you have a sample bank document imaging policy that we can use?”

We hear this question quite often here at AccuSystems. And, perhaps for good reason. Although digitizing your bank’s loans, deposits, and trusts is an excellent way to reduce risk and boost efficiency, doing so does yield a few new obligations. One such obligation is the creation of and adherence to a bank document imaging policy.

In this article, I’ll share my thoughts about bank document imaging policies and tips for creating a policy that works for your financial institution.

What is a Bank Document Imaging Policy?

A bank imaging policy is a document that sets forth formal guidelines for the financial institution’s imaging program. A well-crafted imaging policy should provide staff with clear answers to questions, such as:

  • Do we need to retain hard copy versions of certain documents?
  • If so, how long must we retain source documents after they are imaged into the system?
  • What is our QC (quality control) policy?
  • How quickly should items be QC’d after being scanned into the system?
  • Do we need to QC 100% of our scanned documents, or just “critical” documents?
  • How will we ensure proper separation of duties to prevent imaging errors and oversights?
  • Which positions are allowed to scan documents into the system?

An imaging policy is different from your bank’s retention policy, but examiners will certainly check to see if you’re following your own rules. If, for example, your imaging policy stipulates that all loan documents must be QC’d within seven days of being boarded, it’s important to have the necessary procedures and tracking mechanisms in place to ensure policy compliance.

Policy vs. Procedures

Speaking of procedures, bankers sometimes confuse the terms “policies” and “procedures.” With regard to imaging, a procedure supports the policy by providing detailed, position-specific work instructions. Procedures might explain how to upload individual documents, scan barcoded documents, save and index customer correspondence, validate image quality, resolve missing document exceptions, generate notice letters, onboard new scanning users, and other related tasks.

For example, when it comes to confirming image quality, the FFIEC’s Operations Booklet states:

“Procedures should be in place to prevent destruction of original documents before verifying image quality, especially when the imaged information is used to process transactions.”

Source: Operations Booklet, Federal Financial Institutions Examination Council (FFIEC) Information Technology Examination Handbook (IT Handbook)

Of course, as with most processes at your bank, adequate procedure training is a key element of success. As the FFIEC points out here, “Inadequate instruction for imaging procedures could lead to quality control issues and misplaced or unavailable data.” In other words, imaging procedures offer minimal value to your financial institution unless staff know they exist and understand how to follow them.

Let’s Talk About Your Imaging Policy

Is your bank thinking about the switch to a bank-wide imaging system, such as our AccuAccount platform? Need someone to bounce a few questions off of?

Let’s connect to discuss how to reduce risk and increase productivity at your bank.

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Connect with Cathy Cirullo

Cathy Cirullo is the Implementation Manager at AccuSystems and has 30+ years of experience working in the banking industry. Having overseen loan operations departments, compliance programs, and retail operations, Cathy has extensive knowledge of loan and deposit documentation and regulations.