Product Updates December 2021

Product Update Blog

Product Updates for December 2021

The Product Updates for December 2021 from feature the following new policy and job description templates, and revised policy template products:

Safeguarding Customer Information Policy Template – NEW!

This new product was developed in response to the FTC’s Final Rule entitled “FTC Strengthens Security Safeguards for Consumer Financial Information Following Widespread Data Breaches” dated 10/27/21 that announced a newly updated rule that strengthens the data security safeguards that financial institutions are required to put in place to protect their customers’ financial information.  In recent years, widespread data breaches and cyberattacks have resulted in significant harms to consumers, including monetary loss, identity theft, and other forms of financial distress.  The FTC’s updated Safeguards Rule requires non-banking financial institutions, such as mortgage brokers, motor vehicle dealers, and payday lenders, to develop, implement, and maintain a comprehensive security system to keep their customers’ information safe.

Information Technology Security Engineer Job Description Template – NEW!

Mortgage Loan Servicing Specialist Job Description Template – NEW!

These new products were developed in response to client requests who submitted their suggestions to our “Client Wish List.”  Your comments and ideas are always greatly appreciated and will be taken into consideration whenever we revise our current products or create new ones.  In summary, we want to ensure your success and earn your business!

Bank Secrecy Act Policy Template – Comprehensive Version

Customer Identification Program Policy Template

The update to these products is in response to the FFIEC Press Release entitled “Federal and State Regulators Release Updates to BSA/AML Examination Manual” dated 12/01/21 that announced updates to the following sections of the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual:

  • Charities and Nonprofit Organizations
  • Independent Automated Teller Machine Owners or Operators
  • Politically Exposed Persons

In addition, the update to the Bank Secrecy Act Policy Template – Comprehensive Version is in response to FinCEN Notice 2021-1 entitled “FBAR Filing Requirement for Certain Financial Professionals” dated 12/13/21 that announced a further extension of time for certain Report of Foreign Bank and Financial Accounts (FBAR) filings in light of the notice of proposed rulemaking (NPRM) FinCEN issued on March 16, 2016, which proposes to revise the regulations implementing the Bank Secrecy Act (BSA) regarding FBARs.

Bank Secrecy Act Policy Template – Comprehensive Version

The update to this products is in response to:

  • FinCEN Notice FIN-2021-A004 entitled “Advisory on Ransomware and the Use of the Financial System to Facilitate Ransom Payments” dated 11/08/21 that updates and replaces its October 1, 2020 Advisory on Ransomware and the Use of the Financial System to Facilitate Ransom Payments.  This updated advisory is in response to the increase of ransomware attacks in recent months against critical U.S. infrastructure, such as the May 2021 ransomware attack that disrupted the operations of Colonial Pipeline, the largest pipeline system for refined oil products in the United States.  This attack led to widespread gasoline shortages that affected tens of millions of Americans.  Other recent targets include entities in the manufacturing, legal services, insurance, financial services, health care, energy, and food production sectors.
  • FinCEN Notice FIN-2021-NTC4 entitled “FinCEN Calls Attention to Environmental Crimes and Related Financial Activity” dated 11/18/21 that calls attention to an upward trend in environmental crimes and associated illicit financial activity.  FinCEN is highlighting this trend because of its strong association with corruption and transnational criminal organizations, two of FinCEN’s national anti-money laundering and countering the financing of terrorism (AML/CFT) priorities, a need to enhance reporting and analysis of related illicit financial flows, and environmental crimes’ contribution to the climate crisis, including threatening ecosystems, decreasing biodiversity, and increasing carbon dioxide in the atmosphere.  The notice provides financial institutions with specific suspicious activity report (SAR) filing instructions and highlights the likelihood of illicit financial activity related to several types of environmental crimes.

Business Continuity Management Policy Template

Cybersecurity Policy Template

Incident Response and Preparedness Policy Template

Information Systems Security Policy Template

Internet Banking Policy Template

Regulation P Policy Template

Unauthorized Access to Customer Information Policy Template

The update to these products is in response to the Joint Release entitled “Agencies Approve Final Rule Requiring Computer-Security Incident Notification” dated 11/18/21 that announced the approval of a final rule to improve the sharing of information about cyber incidents that may affect the U.S. banking system.  The final rule requires a banking organization to notify its primary federal regulator of any significant computer-security incident as soon as possible and no later than 36 hours after the banking organization determines that a cyber incident has occurred.  Notification is required for incidents that have materially affected—or are reasonably likely to materially affect—the viability of a banking organization’s operations, its ability to deliver banking products and services, or the stability of the financial sector.

In addition, the final rule requires a bank service provider to notify affected banking organization customers as soon as possible when the provider determines that it has experienced a computer-security incident that has materially affected or is reasonably likely to materially affect banking organization customers for four or more hours.

Compliance with the final rule is required by May 1, 2022.

Commercial Loan Policy Template

Small Business Administration Loan Policy Template

The update to these products is in response to the SBA’s Press Release entitled “SBA Announces Updated Guidance Regarding Applicant Deadlines for COVID Economic Injury Disaster Loan Program” dated 11/19/21 that announced updated guidance for COVID Economic Injury Disaster Loan (EIDL) program applicants to better serve small business owners in need, while funding remains available.  Since its inception, the COVID EIDL program, a federal disaster relief loan designed to better serve and support small business communities still reeling from the pandemic, especially hard-hit sectors such as restaurants, gyms, and hotels, has approved nearly $300 billion in relief aid.

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.

Foreclosure Policy Template

Mortgage Loan Policy Template

Mortgage Servicing Policy Template

Regulation X Policy Template

The update to these products is in response to the Joint Press Release entitled “Joint Statement on Supervisory and Enforcement Practices Regarding the Mortgage Servicing Rules in Response to the Continuing COVID-19 Pandemic and CARES Act” dated 11/10/21 that issued a joint policy statement to communicate to mortgage servicers the agencies’ supervisory and enforcement approach as risks associated with the Coronavirus Disease (COVID-19) pandemic continue to change.

More than 18 months have passed since issuance of the April 2020 Joint Statement.  While the COVID-19 pandemic continues to affect consumers and mortgage servicers, the agencies believe the temporary flexibility described in the April 2020 Joint Statement is no longer necessary because servicers have had sufficient time to adjust their operations by, among other things, taking steps to work with consumers affected by the COVID-19 pandemic and developing more robust business continuity and remote work capabilities.  Accordingly, the temporary supervisory and enforcement flexibility announced in the April 2020 Joint Statement no longer applies and the agencies will apply their respective supervisory and enforcement authorities, where appropriate, to address any noncompliance or violations of the Regulation X mortgage servicing rules that occur after the date of issuance of this statement.

The agencies recognize the ongoing challenges faced by mortgage servicers and their efforts to assist customers and members affected by the ongoing COVID-19 pandemic.  The agencies continue to encourage mortgage servicers to engage in these efforts.  The agencies will consider, when appropriate, the specific impact of servicers’ challenges that arise due to the COVID-19 pandemic and take those issues in account when considering any supervisory and enforcement actions.  As part of their considerations, the agencies will factor in the time it takes to make operational adjustments in connection with this joint statement.

As a reminder, the complete contents of the Mortgage Loan Servicing Policy Template are included as Topic 18 within the Regulation X Policy Template.  In addition, the complete contents of the Foreclosure Policy Template are included as Topic 22 within the Mortgage Loan Policy Template.

Human Resources Vaccination Policy Template

Human Resources General Policy Template

The update to these products is in response to the U.S. Department of Labor’s New Release entitled “US Department of Labor Issues Emergency Temporary Standard to Protect Workers from Coronavirus” dated 11/04/21 that announced a new emergency temporary standard to protect more than 84 million workers from the spread of the coronavirus on the job.  The nation’s unvaccinated workers face grave danger from workplace exposure to coronavirus, and immediate action is necessary to protect them.  Employers with 100 or more employees must comply by 12/06/21, with the exception of the COVID-19 testing requirements which is 01/04/22.

The complete contents of the new Human Resources Vaccination Policy Template are included as Topic 29 within the Human Resources General Policy Template.

Regulation C Policy Template

As a courtesy, we revised this product to eliminate any regulatory guidance that was in effect prior to the new Home Mortgage Disclosure Act (HMDA) rule that is effective 01/01/22.

Keeping You Informed

We provide this Product Update Blog as a courtesy to all clients regarding new and revised products released by  We feel that it is important to keep our clients well informed of changes to the financial institution industry, including keeping on top of federal regulatory changes, and industry recommended best practices.  In this regard, we encourage you to subscribe to our newsletter in which these types of announcements are made including any special offers that can save you time and money.  Just contact us to be added to our distribution list.

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