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Product Updates April 2018

Product Updates for April 2018

The Product Updates for April 2018 from BankPolicies.com feature the following revised policy template products:

Appraisal Policy Template

The update to this product is in response to the Joint Release entitled “Real Estate Appraisals” issued on 03/15/18 which amends the agencies’ regulations requiring appraisals of real estate for certain transactions.  The final rule increases the threshold level at or below which appraisals are not required for commercial real estate transactions from $250,000 to $500,000.  The final rule defines commercial real estate transaction as a real estate-related financial transaction that is not secured by a single 1-to-4 family residential property.  It excludes all transactions secured by a single 1-to-4 family residential property, and thus construction loans secured by a single 1-to-4 family residential property are excluded.  For commercial real estate transactions exempted from the appraisal requirement as a result of the revised threshold, regulated institutions must obtain an evaluation of the real property collateral that is consistent with safe and sound banking practices.


Cybersecurity Policy Template
Information Systems Security Policy Template

The update to these products is in response to the SEC’s publication in the Federal Register entitled “Commission Statement and Guidance on Public Company Disclosures” dated 02/26/18 that announced interpretive guidance to assist public companies in preparing disclosures about cybersecurity risks and incidents.  This interpretive release outlines the SEC’s views with respect to cybersecurity disclosure requirements under the federal securities laws as they apply to public operating companies.  In addition, the guidance addresses the importance of cybersecurity policies and procedures and the application of insider trading prohibitions in the cybersecurity context.

As a reminder, the complete contents of the Cybersecurity Policy Template are included within the Information Systems Security Policy Template as Topic 29.


Regulation A Policy Template

The update to this product is in response to the Federal Reserve’s Final Rule issued on 03/27/18 that adopted final amendments to its Regulation A to reflect the Federal Reserve Board’s approval of an increase in the rate for primary credit at each Federal Reserve Bank.  The secondary credit rate at each Reserve Bank automatically increased by formula as a result of the Federal Reserve Board’s primary credit rate action.


Regulation D Policy Template

The update to this product is in response to the Federal Reserve’s Final Rule issued on 03/27/17 that revises the rate of interest paid on balances maintained to satisfy reserve balance requirements (“IORR”) and the rate of interest paid on excess balances (“IOER”) maintained at Federal Reserve Banks by or on behalf of eligible institutions.  The final amendments specify that IORR is 1.75 percent and IOER is 1.75 percent, a 0.25 percentage point increase from their prior levels.


Regulation Z Policy Template

The update to this product is in response to the CFPB’s final rule entitled “Mortgage Servicing Rules Under the Truth in Lending Act (Regulation Z)” dated 03/08/18 that amends certain aspects of the mortgage servicing rule issued in 2016 relating to periodic statements.  These amendments revise the timing requirements for servicers transitioning between modified or unmodified periodic statements and coupon books when consumers enter or exit bankruptcy.