Product Updates August 2026
The Product Updates for August 2026 from BankPolicies.com feature the following revised for and policy template products:
Bank Secrecy Act Policy Template – Comprehensive Version
Office of Foreign Assets Control Policy Template
The update to these products is in response to OFAC’s final rule entitled “Updating Website and Contact Information, and Authorizations for Payments for Legal Services” dated 07/27/26 that updates website and contact information in several parts of the Code of Federal Regulations; to amend 31 CFR Part 546 to update general licenses authorizing payments for legal services from funds originating outside the United States to replace the reporting requirement in the general license with a recordkeeping requirement; to correct an erroneous cross-reference in Part 526; and to amend Parts 553 and 598 to correct typographical errors. The changes were effective on 07/27/26.
Bank Secrecy Act Policy Template – Comprehensive Version
Customer Identification Program Policy Template
The update to these products is in response to FinCEN’s final rule entitled “Beneficial Ownership Information Reporting Requirement Revision” dated 08/11/26 that adopts as final and with certain limited changes the interim final rule issued on March 26, 2025, which narrowed beneficial ownership information (BOI) reporting requirements under FinCEN’s regulations implementing the Corporate Transparency Act (CTA). In particular, this final rule not only continues to exempt reporting companies from having to report the BOI of U.S. person beneficial owners and U.S. person beneficial owners from having to provide BOI to reporting companies; it also exempts reporting companies from having to submit information about their U.S. person company applicants to FinCEN and exempts U.S. person company applicants from any obligation to provide their information. In addition, the final rule exempts all U.S. persons from the requirement to update information already provided to FinCEN in connection with obtaining a FinCEN identifier (FinCEN ID).
The final rule is effective on the date of publication in the Federal Register.
BSA Suspicious Activity Report Notices Template
The update to this product is in response to FinCEN Alert FIN-2026-Alert004 entitled “FinCEN Alert on Fraud Schemes Targeting Federal Student Aid” dated 07/24/26 that urges financial institutions to be vigilant in detecting, identifying, and reporting suspicious activity connected to fraud schemes targeting U.S. Department of Education’s (ED) Office of Federal Student Aid (FSA) programs. Fraud rings use stolen and fraudulent identities, as well as other tactics, to enroll in educational institutions and unlawfully acquire funds from federal student aid programs. The schemes not only result in losses to federal student aid programs, but also, in some cases, real students face difficulties enrolling in classes because of the number of fraudulently enrolled “students.”
Commercial Loan Policy Template
Commercial Real Estate Loan Policy Template
The update to these products is in response to the “Interagency Guidance on Lending to Individuals Not Legally Authorized to Work in the United States.” On May 19, 2026, the President issued the Executive Order, “Restoring Integrity to America’s Financial System,” to address risks to the financial system posed by the extension of credit or financial services to the inadmissible and removable population. In accordance with the Executive Order, the Office of the Comptroller of the Currency, Treasury (OCC), the Federal Deposit Insurance Corporation (FDIC), and the National Credit Union Administration (NCUA) (collectively, the agencies) are issuing this guidance to remind supervised financial institutions of their existing obligations with respect to credit risk management, particularly as it relates to borrowers who are not legally authorized to work in the United States (non-work authorized borrowers).
Compliance Management Policy Template
The update to this product is in response to the Joint Press Release entitled “Statement Regarding Coordinated Federal Banking Agency Approach for the Handling of Highly Sensitive Information During Examinations” dated 07/16/26 that announced a coordinated approach for the handling of highly sensitive information during examinations of supervised banks. This communication provides information to supervised banks on this coordinated approach, how it is being rolled out across the federal banking agencies (FBAs) and their supervisory personnel, and the role that supervised banks may play in implementation.
Current Expected Credit Losses Policy Template
The update to this product is in response to OCC Bulletin 2026-33 entitled “Allowances for Credit Losses: Revised Comptroller’s Handbook and Rescissions” dated 07/16/26 that provides information regarding allowances for credit losses (ACL) under Accounting Standards Codification (ASC) Topic 326, “Financial Instruments—Credit Losses.” In addition, the following are rescinded with the issuance of this booklet:
- Version 1.0 of the “Allowances for Credit Losses” booklet of the Comptroller’s Handbook.
- OCC Bulletin 2021-20, “Allowances for Credit Losses: New Comptroller’s Handbook Booklet,” which transmitted version 1.0 of this booklet.
- The “Allowance for Loan and Lease Losses” booklet of the Comptroller’s Handbook.
- The July 1996 cover letter that transmitted the “Allowance for Loan and Lease Losses” booklet.
Keeping You Informed
We provide this Product Update Blog to keep clients informed of newly released and updated BankPolicies.com products. Staying current with regulatory changes and industry best practices is essential, and our updates are designed to support that effort. To receive these announcements and occasional special offers, we invite you to subscribe to our newsletter. Simply contact us to be added to our distribution list.