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