Product Updates for April 2021
The Product Updates for April 2021 from BankPolicies.com feature the following new job description templates, new policy template, and revised policy template products:
These new and revised products were developed in response to client requests who submitted their suggestions to our “Client Wish List” that we create an Active Shooter Policy. In general, an active shooter is defined by U.S. Government agencies as “an individual actively engaged in killing or attempting to kill people in a confined and populated area.” Your comments and ideas are always greatly appreciated and will be taken into consideration whenever we revise our current products or create new ones. In summary, we want to ensure your success and earn your business!
These new products were developed in response to client requests who submitted their suggestions to our “Client Wish List.” Your comments and ideas are always greatly appreciated and will be taken into consideration whenever we revise our current products or create new ones. In summary, we want to ensure your success and earn your business!
The update to this product is in response to NACHA’s News Release entitled “Same Day ACH Payment Limit to Increase to $1 Million” dated 04/05/21 that announced NACHA members approved a measure to increase the per-payment maximum from the current $100,000 to $1 million effective March 18, 2022 which will apply to all eligible Same Day ACH payments, including credits and debits for both businesses and consumers.
The update to these products is in response to OFAC’s Final Rules:
“Inflation Adjustment of Civil Monetary Penalties” dated 03/16/21 that adjusts for inflation the maximum amount of the civil monetary penalties that may be assessed under relevant OFAC regulations. This regulatory amendment is currently available for public inspection with the Federal Register and will take effect upon publication in the Federal Register on Wednesday, March 17, 2021.
“Adjustment of Applicable Schedule Amount” dated 04/09/21 that issued a final rule to make a technical amendment to the definition of “applicable schedule amount” in its regulations. In recent years, OFAC has adjusted its civil monetary penalties (CMPs) as required by the Federal Civil Penalties Inflation Adjustment Act, as amended by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. While OFAC’s “applicable schedule amount” values are not civil monetary penalties that are required to be adjusted pursuant to such statute, OFAC is making a technical change to this definition to ensure the applicable schedule amount values continue to correspond appropriately to OFAC’s CMPs.
As a reminder, the complete contents of the Office of Foreign Assets Control Policy Template are included as Topic 19 within the Bank Secrecy Act Policy Template – Comprehensive Version.
The update to these products is in response to the SBA’s Press Release entitled “SBA Extends Deferment Period for all COVID-19 EIDL and Other Disaster Loans Until 2022” dated 03/16/21 that announced extended deferment periods for all disaster loans, including the COVID-19 Economic Injury Disaster Loan (EIDL) program, until 2022:
All SBA disaster loans made in calendar year 2020, including COVID-19 EIDL, will have a first payment due date extended from 12-months to 24-months from the date of the note.
All SBA disaster loans made in calendar year 2021, including COVID-19 EIDL, will have a first payment due date extended from 12-months to 18-months from the date of the note.
In addition, both products were revised in response to the President of the United States signing into law on 03/30/21 H.R. 1799, the “PPP Extension Act of 2021,” which extends the Paycheck Protection Program (PPP) application deadline to May 31, 2021; and extends the PPP authorization through June 30, 2021 to provide the Small Business Administration additional time to process applications received by the application deadline.
As a reminder, the complete contents of the Small Business Administration Loan Policy Template are included as Topic 19 within the Commercial Loan Policy Template.
The update to this product is in response to the CFPB’s Press Release entitled “CFPB Rescinds Series of Policy Statements to Ensure Industry Complies with Consumer Protection Laws” dated 03/31/21 that announced it is rescinding seven policy statements issued last year that provided temporary flexibilities to financial institutions in consumer financial markets including mortgages, credit reporting, credit cards and prepaid cards. The seven rescissions, effective April 1, provide guidance to financial institutions on complying with their legal and regulatory obligations. With the rescissions, the CFPB is providing notice that it intends to exercise the full scope of the supervisory and enforcement authority provided under the Dodd-Frank Act. The CFPB is also rescinding its 2018 bulletin on supervisory communications and replacing it with a revised bulletin describing its use of matters requiring attention (MRAs) to effectively convey supervisory expectations.
The update to this product is in response to OCC Bulletin 2021-11 entitled “Servicemembers Civil Relief Act: Revised Comptroller’s Hand Booklet and Rescissions” dated 03/04/21 that announced a revised “Servicemembers Civil Relief Act” booklet of the Comptroller’s Handbook. This booklet provides information and procedures in connection with the consumer protections that servicemembers are eligible for under the Servicemembers Civil Relief Act (SCRA). With the issuance of this revised booklet, the following documents are rescinded:
OCC Bulletin 2011-16, “Servicemembers Civil Relief Act: Revised Examination Procedures”
“Servicemembers Civil Relief Act of 2003” booklet of the Comptroller’s Handbook issued in May 2011
Keeping You Informed
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