Product Updates for August 2021
The Product Updates for August 2021 from BankPolicies.com feature the following new and revised policy template products:
These new and updated products are in response to the FFIEC’s “Revision of the Operations Booklet and Name Change to Architecture, Infrastructure, and Operations Booklet” dated 06/30/21 that announced a revised and renamed Operations booklet to Architecture, Infrastructure, and Operations (AIO) to reflect the changing technological environment and increasing need for security and resilience, including architectural design, infrastructure implementation, and operation of information technology systems, and it provides examiners and financial institution with fundamental examination expectations regarding architecture and infrastructure planning, governance and risk management, and operations of regulated entities. The new handbook can be found here.
As a reminder, the complete contents of the Systems Development and Acquisition Policy Template, Cloud Computing Policy Template, and Information Technology Audit Policy Template are included as Topics 38, 35, and 44 within the Information Systems Security Policy Template.
The update to these products is in response to the OCC Bulletin 2021-34 entitled “Small Business Administration Lending: Risk Management Principles” dated 08/05/21 that informs banks and examiners about sound risk management principles associated with engaging in U.S. Small Business Administration (SBA) guaranteed lending programs. A bank’s SBA lending activities, including purchasing investments backed by SBA-guaranteed loans, should be consistent with the bank’s overall business plans, strategies, risk appetite, and sound risk management.
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 these products is in response to the FDIC’s “Risk Management of Examination Policies” dated 07/21/21 that announced an update to Section 4.1 of the manual to include enhancements to the discussions on dominant official, key person dependency risk, strategic planning, and selecting and retaining competent management.
The update to this product is in response to the Federal Reserve’s Final Rule issued on 07/23/21 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 0.15 percent and IOER is 0.15 percent, a 0.05 percentage point increase from their prior levels.
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