Product Updates December 2025
The Product Updates for December 2025 from BankPolicies.com feature the following revised policy template products:
Cryptocurrency Policy Template
The update to this product is in response to OCC Interpretive Letter #1186 entitled “Authority of National Banks to Hold Crypto-Assets as Principal and Pay Crypto-Asset Network Fees as Incidental to a Permissible Banking Activity” dated 11/18/25 that a national bank may pay network fees, sometimes referred to as “gas fees,” on blockchain networks to facilitate otherwise permissible activities and hold, as principal, amounts of crypto-assets on balance sheet necessary to pay network fees for which the bank anticipates a reasonably foreseeable need. In addition, the OCC confirms that a national bank may hold amounts of crypto-assets as principal necessary for testing otherwise permissible crypto-asset-related platforms, whether internally developed or acquired from a third-party.
As with any activity, a national bank must conduct these activities in a safe and sound manner and in compliance with applicable law.
FDIC Advertising Policy Template
Marketing Plan and Program Policy Template
The update to these products is in response to the FDIC’s FIL-53-2025 entitled “Compliance Date Extension: Sections 328.4 and 328.5 Amendments to FDIC Official Signs and Advertising Requirements, False Advertising, Misrepresentation of Insured Status, and Misuse of the FDIC’s Name or Logo Rule” dated 11/25/25 that extends the compliance date from March 1, 2026, to January 1, 2027, for the requirements under 12 CFR 328.5 to display the FDIC official digital sign on an insured depository institution’s (IDI’s) digital deposit-taking channels, as well as analogous requirements related to IDI’s automated teller machines (ATMs) and like devices under 12 CFR 328.4. This extension aligns the compliance date with the FDIC’s proposal issued earlier this year that would make adjustments to those provisions.
The update to this product is in response to the Federal Reserve’s Final Rule dated 11/24/25 that amends Regulation D, Reserve Requirements of Depository Institutions, to reflect the annual indexing of the reserve requirement exemption amount and the low reserve tranche for 2026. The annual indexation of these amounts is required notwithstanding the Federal Reserve Board’s action in March 2020 of setting all reserve requirement ratios to zero. The Federal Reserve Board is amending Regulation D to set the reserve requirement exemption amount at $39.2 million (increased from $37.8 million in 2025) and the amount of the low reserve tranche at $674.1 million (increased from $645.8 million in 2025). The adjustments to these amounts are derived using statutory formulas specified in the Federal Reserve Act (the ‘‘Act’’). The annual indexation of the reserve requirement exemption amount and low reserve tranche is required by statute but will not affect depository institutions’ reserve requirements, which will remain zero.
The effective date is December 24, 2025, and compliance date of the new exemption amount and low reserve tranche will apply beginning January 1, 2026.
Servicemembers Civil Relief Act Policy Template
The update to this product is in response to OCC Bulletin 2025-36 entitled “Servicemembers Civil Relief Act: Updated Comptroller’s Handbook Booklet” dated 11/13/25 that announced a revised version 1.1 of the “Servicemembers Civil Relief Act” booklet of the Comptroller’s Handbook. The booklet provides information and procedures for examiners in connection with the consumer protections that servicemembers are eligible for under the Servicemembers Civil Relief Act (SCRA).
The updated booklet replaces version 1.0 of the booklet with the same title issued March 2021. In addition, the OCC rescinded Bulletin 2021-11, “Servicemembers Civil Relief Act: Revised Comptroller’s Handbook Booklet and Rescissions,” which transmitted version 1.0 of the booklet.
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