Product Updates February 2015

New and Revised Policy Templates for February 2015

Litigation Risk Management Program Policy Template

This new product was developed in response to the OCC’s Bulletin 2015-04 dated 01/16/15 that announced the revised “Litigation and Other Legal Matters” booklet of the Comptroller’s Handbook. The revised booklet includes guidance regarding a financial institution’s requirement to have policies and processes in place to reduce the likelihood of litigation to prevent undue harm to a bank’s reputation, control expenses associated with litigation, and mitigate potential liabilities.

Interest Rate Risk Policy Template

The update to this product is in response to the FDIC’s “Supervisory Insights – Winter 2014” publication dated 12/18/14 which provides enhanced and detailed guidance regarding a financial institution’s requirement to maintain an effective interest rate risk (IRR) management process through the establishment of board approved policies that measure, monitor, and control IRR. As discussed in this article, a successful governance framework is grounded in an informed and involved board of directors that provides senior management with clear policy guidance, sufficient internal resources, and risk mitigation strategies to guide an institution’s IRR position well in advance of market shifts.

Regulation X (RESPA) Policy Template
Regulation Z Policy Template

The update to these products is in response to the CFPB’s release entitled “CFPB Finalizes Minor Changes to Know Before You Owe Mortgage Rules“ dated 01/20/15 that address when consumers will receive updated disclosures after locking in an interest rate, and how consumers receive information regarding certain construction loans.