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Product Updates August 2018

Product Updates for August 2018

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

Acquisition, Development, and Construction (ADC) Loan Policy Template
Appraisal Policy Template
Commercial Real Estate Loan Policy Template
Corporate Governance Policy Template
Stress Testing Program Policy Template

The update to these products is in response to the Joint Release entitled “Agencies Issue Statement Regarding the Impact of the Economic Growth, Regulatory Relief, and Consumer Protection Act” dated 07/06/18 that details rules and associated reporting requirements that are immediately affected by the enactment of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA).  These changes affect company-run stress testing, resolution plans, the Volcker rule, high volatility commercial real estate exposures, examination cycles, municipal obligations as high-quality liquid assets, and other provisions.  The statement from the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency describes interim positions the regulatory agencies will take before incorporating the changes into their regulations.


Complaint Policy Template
Compliance Management Policy Template

The update to these products is in response to the OCC’s Bulletin 2018-18 that announced the availability of a revised “Compliance Management Systems” booklet of the Comptroller’s Handbook.  The revised and updated booklet replaces the booklet of the same title previously issued.


Fair Lending Policy Template
Unfair or Deceptive Acts or Practices (UDAP) Policy Template

The update to these products is in response to the Federal Reserve’s Press Release entitled “Federal Reserve Board Launches Consumer Compliance Supervision Bulletin” dated 07/26/18 that announced a new publication that will provide bankers and others interested in consumer protection with high-level summaries of pertinent supervisory issues.  The Bulletin complements other Federal Reserve System outreach programs for banking organizations, such as the Consumer Compliance Outlook publication and its companion webinar series, Outlook Live.


Regulation C Policy Template

The update to this product is in response to the CFPB’s statement entitled “Bureau of Consumer Financial Protection Issues State on the Implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act Amendments to the Home Mortgage Disclosure Act” dated 07/05/18 that announced on May 24, 2018, the President signed the Economic Growth, Regulatory Relief, and Consumer Protection Act (the Act), a section of which amends the Home Mortgage Disclosure Act (HMDA).  The Act provides partial exemptions for some insured depository institutions and insured credit unions from certain HMDA requirements.  The partial exemptions are generally available to insured depository institutions and insured credit unions for:

  • Closed-end mortgage loans if the institution originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years.
  • Open-end lines of credit if the institution originated fewer than 500 open-end lines of credit in each of the two preceding calendar years.

For closed-end mortgage loans or open-end lines of credit subject to the partial exemptions, the Act states that the “requirements of [HMDA section 304(b)(5) and (6)]” shall not apply.  Accordingly, for these transactions, those institutions are exempt from the collection, recording, and reporting requirements for some, but not all, of the data points specified in current Regulation C.

The CFPB expects later this summer to provide further guidance on the applicability of the Act to HMDA data collected in 2018.