"Best Practices"...

"Best practices" seems to be the favorite "be all, end all" justification for regulatory insensibility of late.  

The increasingly common answer to the legitimate question: "Why?" from a Credit Union Board or staff to a supervisory examiner is: "Best practices!"  

When pressed for where that little list of "best practices" might be found; and, who and how the "best practices" list was compiled, the supervisory examiner's memory inevitably becomes somewhat distant and vague.  Some have been known to become wild-eyed and to start "speaking in tongues" (that means "gibberish" for those of you who do not handle snakes in connection with your religious practices.)   

The vast majority of examiners are competent, reasonable, responsible human beings who realize that an honest answer would be: "I have absolutely no earthly idea;  that's all we were told".  

Unfortunately, too often the answer given is " a larry":  "They said" it was in the rules somewhere. "They said" everybody should know what "best practices" are. "They said" it wasn't our responsibility to keep up with "best practices", it was yours.  

So, just how are those "best practices" determined?  And, what is the thought behind not being transparent about these issues? Here are your five choices...

1)

2)

3)

4)

5)

... but the [most "robust"] "best practices" answer is

"All of the above"!