Product Updates for April 2024
The Product Updates for April 2024 from BankPolicies.com feature the following new and revised form and policy template products:
Community Reinvestment Act Policy Template
The update to this product is in response to the Joint Press Release entitled “Agencies Extend Applicability Date of Certain Provisions of Their Community Reinvestment Act Final Rule” dated 03/21/24 that issued an interim final rule that extends the applicability date of certain provisions in their Community Reinvestment Act (CRA) final rule issued in October 2023. The agencies also requested comment on the extension.
To promote clarity and consistency, the agencies extended the applicability date of the facility-based assessment areas and public file provisions from April 1, 2024, to January 1, 2026. Therefore, banks will not have to make changes to their assessment areas or their public files as a result of the 2023 CRA final rule until January 1, 2026. This extension aligns these provisions with other substantive parts of the 2023 CRA final rule that are applicable on January 1, 2026. For example, all provisions about where banks are evaluated will now apply on the same date. Comments on the extended applicability date must be received 45 days after the rule is published in the Federal Register.
In addition, the agencies also issued technical, non-substantive amendments to the CRA final rule and related agency regulations that reference it. For example, one of these technical amendments clarifies that banks do not need to make changes to their public notices until January 1, 2026.
FDIC Advertising Policy Template
Marketing Plan and Program Policy Template
Unfair or Deceptive Acts or Practices (UDAP) Policy Template
The update to these products is in response to the FDIC’s FIL-16-2024 entitled “FDIC Consumer Compliance Supervisory Highlights – March 2024 Edition” dated 03/28/24 that provides an overview of consumer compliance issues identified through the FDIC’s supervision of state non-member banks and thrifts in 2023. This edition of the FDIC’s Consumer Compliance Supervisory Highlights includes:
- A description of the most frequently cited violations and other consumer compliance examination observations;
- Information on regulatory developments;
- A summary of consumer compliance resources and information available to financial institutions; and
- An overview of consumer complaint trends.
Human Resources General Policy Template
Human Resources Workplace Violence Prevention Policy Template – NEW!
Human Resources Workplace Violence Incident Log Form Template – NEW!
These new and updated products are in response to the expansion of detail regarding a financial institution’s Workplace Violence Prevention Plan for additional clarity, current industry best practices, and those of originating from client requests.
The complete contents of the new Human Resources Workplace Violence Prevention Policy Template are included in the Human Resources General Policy Template as Topic 24.
Mortgage Servicing Policy Template
The update to these products is in response to the deletion of guidance regarding Coronavirus/COVID-19 applicability.
As a reminder, the complete contents of the Mortgage Servicing Policy Template are included within the Regulation X Policy Template as Topic 18.
Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) Policy Template
The update to this product is in response to the CFPB’s Consumer Financial Protection Circular 2024-02 entitled “Deceptive Marketing Practices About the Speed and Cost of Sending a Remittance Transfer” dated 03/27/24 that provides guidance regarding when remittance transfer providers violate the prohibition on deceptive acts or practices in the Consumer Financial Protection Act (CFPA) in their marketing about the speed and cost of sending a remittance transfer.
Keeping You Informed
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