Product Updates December 2015

BankPolicies.com is providing you with these product updates as a courtesy to all of our clients. If you have any questions, please contact us.

Revised Policy Templates

The update to these products is in response to the OCC’s Bulletin 2015-39 dated 10/27/15 that announced the issuance of a revised Floor Plan Lending booklet which provides an overview of the floor plan lending business, associated risks, and sound risk management practices for financial institutions.

In addition, the update to the Commercial Loan Policy Template is in response to the FDIC’s FIL-49-2015 entitled “Advisory on Effective Risk Management Practices for Purchased Loans and Purchased Loan Participations” dated 11/06/15 that addresses purchased loans and loan participations and reminds financial institutions of the importance of underwriting and administering these purchased credits as if the loans were originated by the purchasing institution. In addition, the advisory reminds financial institutions that third party arrangements to facilitate loan and loan participation purchases should be managed by an effective third-party risk management process.

As a reminder, the complete contents of the Flooring Lines of Credit Policy Template are included in the Commercial Loan Policy Template as Topic 11.


The update to these products is in response to the FFIEC’s Press Release entitled “FFIEC Release Statement on Cyber-Attacks Involving Extortion” dated 11/03/15 that alerts financial institutions to the increasing frequency and severity of cyber-attacks involving extortion. The statement describes steps financial institutions should take to respond to these attacks and highlights resources institutions can use to mitigate the risks posed by such attacks.


Regulation D Policy Template

This product was revised in response to the Federal Reserve’s Press Release dated 11/12/15 that announced the annual indexing of two amounts used in determining reserve requirements of depository institutions. These amounts are the reserve requirement exemption amount and the low reserve tranche.