New and Revised Policy Templates for February 2017
This new product was developed in response to client requests and OCC Bulletin 2017-4 that announced a revised “Management Interlocks” booklet which provides updated requirements following the integration of the Office of Thrift Supervision into the OCC in 2011 and clarifies guidance for both national banks and federal savings associations.
This product was revised in response to OCC Bulletin 2016-42 that announced a revised “Internal and External Audits” booklet which provides updated guidance for assessing audit exposures, associated risks, and risk management practices. In addition, the booklet establishes supervisory expectations for managing internal and external audit risk, and includes expanded examination procedures to assess the effectiveness of the audit functions and their impact on the quantity of risk and quality of risk management.
The update to this product is in response to the FinCEN’s news release entitled “FBAR Filing Requirement for Certain Financial Professionals“ dated 12/16/16 that announces 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 10, 2016, which proposes to revise the regulations implementing the Bank Secrecy Act (BSA) regarding FBARs.
The update to this product is in response to the Joint Release entitled “Joint News Release: Agencies Release Annual CRA Asset-Size Threshold Adjustments for Small and Intermediate Small Institutions” that announced the annual adjustment to the asset-size thresholds used to define small bank, small savings association, intermediate small bank, and intermediate small savings association under the Community Reinvestment Act (CRA) regulations.
This product was revised in response to the Federal Reserve’s Final Rule dated 01/23/17 that amended Regulation A (Extensions of Credit by Federal Reserve Banks) to reflect the Federal Reserve Board’s approval of an increase in the rate for primary credit at each Federal Reserve Bank. The secondary credit rate at each Reserve Bank automatically increased by formula as a result of the Federal Reserve Board’s primary credit rate action.
This product was revised in response to the Federal Reserve’s Final Rule dated 01/23/17 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.