Product Updates for February 2021
The Product Updates for February 2021 from BankPolicies.com feature the following revised policy template products:
Bank Secrecy Act Policy Template – Comprehensive Version
The update to these products is in response to FinCEN Advisory FIN-2021-A001 entitled “Advisory on COVID-19 Health Insurance- and Health Care-Related Fraud” dated 02/02/21 to alert financial institutions to health insurance and health care frauds related to the COVID-19 pandemic.
Commercial Loan Policy Template
Small Business Administration Loan Policy Template
The update to these products is in response to the SBA’s interim final rule entitled “Business Loan Program Temporary Changes; Paycheck Protection Program – Loan Forgiveness Requirements and Loan Review Procedures as Amended by Economic Aid Act” dated 01/19/21 that implements changes related to the forgiveness and review of loans made under the Paycheck Protection Program (PPP), which was originally established under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) to provide economic relief to small businesses nationwide adversely impacted by the Coronavirus Disease 2019 (COVID-19). This interim final rule consolidates prior rules related to forgiveness and reviews of PPP loans and incorporates changes made by the Economic Aid Act, including with respect to forgiveness of second draw PPP loans.
As a reminder, the complete contents of the Small Business Administration Loan Policy Template are included as Topic 19 within the Commercial Loan Policy Template.
Compliance Management Policy Template
The update to this product is in response to the CFPB’s Notice entitled “Statement Regarding the Provision of Financial Products and Services to Consumers with Limited English Proficiency” dated 01/13/21 that issued a Statement Regarding the Provision of Financial Products and Services to Consumers with Limited English Proficiency (Statement) to encourage financial institutions to better serve consumers with limited English proficiency (LEP) and to provide principles and guidelines to assist financial institutions in complying with the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the Equal Credit Opportunity Act (ECOA), and other applicable laws.
Regulation O and Insider Activity Policy Template
The update to this product is in response to the Federal Reserve’s Press Release entitled “Federal Reserve Board Announces the Second Extension of a Rule to Bolster the Effectiveness of the Small Business Administration’s Paycheck Protection Program (PPP)” dated 02/09/21 that announced the second extension of a rule to bolster the effectiveness of the Small Business Administration’s (SBA) Paycheck Protection Program (PPP). Like the earlier extensions, this one will temporarily modify the Board’s rules so that certain bank directors and shareholders can apply to their banks for PPP loans for their small businesses. The rule extension is effective immediately and applies to PPP loans made through March 31, 2021.
The update to this product is in response to a final rule issued by the CFPB entitled “Higher-Priced Mortgage Loan Escrow Exemption (Regulation Z)” dated 01/19/21 that amends Regulation Z, which implements the Truth in Lending Act, as mandated by section 108 of the Economic Growth, Regulatory Relief, and Consumer Protection Act. The amendments exempt certain insured depository institutions and insured credit unions from the requirement to establish escrow accounts for certain higher-priced mortgage loans. This rule is effective on publication in the Federal Register.
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