Product Updates December 2025
The Product Updates for December 2025 from BankPolicies.com feature the following revised policy template products:
Bank Secrecy Act Policy Template – Comprehensive Version
The update to this product is in response to FinCEN Notice FIN-2025-NTC3 entitled “FBAR Filing Requirement for Certain Financial Professionals: Extended Filing Date Related to FIN-2024-NTC7” dated 12/08/25 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.
Capital Planning Policy Template
Corporate Governance Policy Template
The update to these products is in response to the Joint Release entitled “Agencies Issue Final Rule to Modify Certain Regulatory Capital Standards” dated 11/25/25 that modifies certain regulatory capital standards to reduce disincentives a banking organization may have to engage in lower-risk activities, such as intermediating in U.S. Treasury markets. The final rule will take effect on April 1, 2026, and banking organizations may elect to adopt the modified standards beginning January 1, 2026.
Corporate Account Takeover Policy Template
The update to this product is in response to the FBI’s Public Service Announcement Alert I-112525-PSA entitled “Account Takeover Fraud via Impersonation of Financial Institution Support” dated 11/25/25 that warns of cyber criminals impersonating financial institutions to steal money or information in Account Takeover (ATO) fraud schemes. The cyber criminals target individuals, businesses, and organizations of varied sizes and across sectors. In ATO fraud, cyber criminals gain unauthorized access to the targeted online financial institution, payroll, or health savings account, with the goal of stealing money or information for personal gain. Since January 2025, the FBI Internet Crime Complaint Center (IC3) received more than 5,100 complaints reporting ATO fraud, with losses exceeding $262 million.
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.
Current Expected Credit Losses Policy Template
The update to this product is in response to FASB Accounting Standards Update (ASU) No. 2025-08 entitled “Financial Instruments – Credit Losses (Topic 326) Purchased Loans” dated November 2025 that expand the population of acquired financial assets subject to the gross-up approach in Topic 326, thus effectively ending the “CECL double count” that often applies to purchased loans in bank mergers. The ASU is effective for annual reporting periods beginning after 12/15/26, though early adoption is permitted.
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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