New and Revised Policy Templates for February 2016
The new Acceptable Use Policy Template was developed in response to client requests to provide a standalone policy that addresses the acceptable use of a financial institution’s information technology resources by internal or external personnel. In addition, we updated the Information Systems Security Policy Template to incorporate additional guidance regarding this subject matter contained in the new product.
The update to this product is in response to the FDIC’s FIL-59-2015 entitled “Revised Compliance Examination Manual” dated 12/04/15. The revised Compliance Examination Manual reflects recent supervisory guidance and provides guidance to FDIC examination staff for evaluating financial institutions for compliance with the federal consumer protection laws and regulations.
These new and revised products were developed in response to the FDIC’s FIL-9-2016 dated 02/01/16 that announced the availability of their Supervisory Insights – Winter 2015 publication that provides an overview of the marketplace lending model and the associated risks, including those that arise in third-party arrangements. The article also highlights the importance of a pragmatic business strategy and offers resources for bank boards of directors and management teams to consider when engaging in marketplace lending activity.
This product was revised in response to the Federal Reserve’s Final Rule dated 12/22/15 that amended Regulation D (Reserve Requirements of Depository Institutions) to revise the rate of interest paid on balances maintained to satisfy reserve balance requirements (“IORR”) and the rate of interest paid on excess balances (“IOER”) maintained at Federal Reserve Banks by or on behalf of eligible institutions.