Product Updates April 2026

The Product Updates for April 2026 from BankPolicies.com feature the following revised policy and form template products:

The update to these products is in response to FDIC FIL-13-2026 entitled “Agencies Issue Final Rule to Prohibit Use of Reputation Risk by Regulators” and OCC Bulletin 2026-12 entitled “Prohibition on Use of Reputation Risk by Regulators: Final Rule” dated 04/07/26 that announced a final rule to codify the removal of reputation risk from their supervisory programs. In general, the final rule:

Prohibits the agencies from criticizing, formally or informally, or taking adverse action against a supervised institution or any employee of an institution on the basis of reputation risk.

Prohibits the agencies from requiring, instructing, or encouraging an institution to close customer accounts or take other actions on the basis of a person’s or entity’s political, social, cultural, or religious views or beliefs, constitutionally protected speech, or solely on the basis of politically disfavored but lawful business activities perceived to present reputation risk.

Does not impose requirements or obligations on supervised institutions.

Defines “reputation risk” as any risk, regardless of how that risk is labeled, that an action or activity of an institution could negatively impact public perception of the institution for reasons not clearly and directly related to the financial or operational condition of the institution.

The final rule takes effect 60 days after the date of publication in the Federal Register.

NOTE: We will continue to issue updates to several of our other products affected by this regulatory guidance over the next few releases and we appreciate your patience.

BSA Suspicious Activity Report Notices Template

The update to this product is in response to FinCEN Advisory FIN-2026-A001 entitled “FinCEN Advisory on Health Care Fraud Schemes Targeting Medicare, Medicaid, and Other Federal and State Health Care Benefit Programs” dated 03/30/26 that urges financial institutions to be vigilant in identifying and reporting suspicious transactions potentially related to health care fraud schemes targeting Medicare, Medicaid, and other federal and state health care benefit programs (hereafter “Health Care Benefit Programs”). This advisory builds on Treasury’s work to combat the potentially billions of dollars in rampant health care and government benefits fraud in Minnesota and across the country.

Overdraft Policy Template

The update to this product is in response to FDIC FIL-14-2026 entitled “FDIC Rescinds Regulatory Guidance on Multiple Re-Presentment NSF Fees” dated 04/10/26 that immediately rescinds FIL-32-2023 dated 06/16/23 entitled “FDIC Clarifying Supervisory Approach Regarding Supervisory Guidance on Multiple Re-Presentment NSF Fees” which described the FDIC’s supervisory approach relating to supervised institutions assessing multiple non-sufficient funds (NSF) fees arising from the re-presentment of the same unpaid transaction.

Keeping You Informed

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Product Updates April 2026

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