Product Updates December 2024
The Product Updates for December 2024 from BankPolicies.com feature the following revised policy and form template products:
The update to this product is in response to The Institute of Internal Auditors (IIA) “Global Internal Audit Standards” that is effective January 1, 2025 that guide the worldwide professional practice of internal auditing and serve as a basis for evaluating and elevating the quality of the internal audit function. The standards are 15 guiding principles that enable effective internal auditing and are set according to a due process followed by the International Internal Audit Standards Board and overseen by the IPPF Oversight Council.
Bank Secrecy Act Policy Template – Comprehensive Version
The update to this product is in response to FinCEN Notice FIN-2024-NTC7 entitled “FBAR Filing Requirement for Certain Financial Professionals: Extended Filing Date Related to FIN-2023-NTC5” dated 11/20/24 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 Security Program Policy Template
Elder Abuse and Larcenies Against Customers Policy Template
The update to these products is in response to the Joint Release entitled “Interagency Statement on Elder Financial Exploitation” dated 12/04/24 that provides supervised institutions with examples of risk management and other practices that may be effective in combatting elder financial exploitation.
Banks, credit unions, and other supervised institutions play an important role in combatting elder financial exploitation and supporting their customers who experience these crimes. The statement provides examples of risk management and other practices that supervised institutions may use to help identify, prevent, and respond to elder financial exploitation.
BSA Suspicious Activity Report Notices Template
The update to this product is in response to FinCEN Alert FIN-2024-Alert004 entitled “FinCEN Alert on Fraud Schemes Involving Deepfake Media Targeting Financial Institutions” dated 11/13/24 that helps financial institutions identify fraud schemes associated with the use of deepfake media created with generative artificial intelligence (GenAI) tools. This alert explains typologies associated with these schemes, provides red flag indicators to assist with identifying and reporting related suspicious activity, and reminds financial institutions of their reporting requirements under the Bank Secrecy Act (BSA). This alert is also part of the U.S. Department of the Treasury’s broader effort to provide financial institutions with information on the opportunities and challenges that may arise from the use of AI.
As a reminder, the BSA Suspicious Activity Report Notices Template is included in the purchase price of the Bank Secrecy Act Policy Template – Comprehensive Version.
Human Resources Salary Administration Policy Template
The update to this product is in response to a Texas federal court’s ruling which struck down a U.S. Department of Labor (DOL) rule entitled “Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales, and Computer Employees” dated 04/23/24 that raised the minimum salary required to be paid to most employees classified as exempt from overtime and minimum wage requirements under the Fair Labor Standards Act (FLSA). The court’s decision blocks the minimum compensation increases that were scheduled to go into effect on January 1, 2025, and invalidates the previously required July 1, 2024 increases nationwide.
The update to this product is in response to the Federal Reserve’s Final Rule entitled “Regulation A: Extensions of Credit by Federal Reserve Bank” dated 11/20/24 that announced final amendments to its regulations to reflect the Federal Reserve Board’s approval of a decrease in the rate for primary credit at each Federal Reserve Bank. The secondary credit rate at each Reserve Bank automatically decreased by formula as a result of the Board’s primary credit rate action.
The amendments to part 201 (Regulation A) are effective 11/20/24. The rate changes for primary and secondary credit were applicable on 11/08/24.
The update to this product is in response to the Federal Reserve’s Final Rule entitled “Regulation D: Reserve Requirements of Financial Institutions” dated 11/20/24 that announced final amendments to its regulations to revise the rate of interest paid on balances (“IORB”) maintained at Federal Reserve Banks by or on behalf of eligible institutions. The final amendments specify that IORB is 4.65 percent, a 0.25 percentage point decrease from its prior level. The amendment is intended to enhance the role of IORB in maintaining the federal funds rate in the target range established by the Federal Open Market Committee (“FOMC” or “Committee”).
The amendments to part 204 (Regulation D) are effective 11/20/24. The IORB rate change was applicable on 11/08/24.
Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) Policy Template
Unfair or Deceptive Acts or Practices (UDAP) Policy Template
The update to these products is in response to OCC Bulletin 2024-33 entitled “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or Practices: Updated Comptroller’s Handbook Booklet and Rescissions” dated 12/03/24 that announced version 1.1 of the “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or Practices” booklet of the Comptroller’s Handbook. The booklet contains information regarding supervision of a bank’s practices related to section 5 of the Federal Trade Commission Act, which prohibits banks from engaging in unfair or deceptive acts or practices (UDAP), and sections 1031 and 1036 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which prohibit unfair, deceptive, or abusive acts or practices (UDAAP).
The updated booklet replaces version 1.0 of the booklet with the same title issued June 2020. Also rescinded is OCC Bulletin 2020-65, “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or Practices: New Comptroller’s Handbook Booklet and Rescissions,” which transmitted version 1.0 of the booklet.
The update to this product is in response to the Federal Reserve Financial Services (FRFS) Adoption of the ISO 20022 Message Format for the Fedwire Funds Service in a single-day implementation strategy on March 10, 2025. With this implementation, FRFS will sunset the existing proprietary Fedwire Application Interface Manual (FAIM) format and replace all FAIM messages with ISO 20022 messages.
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