Product Updates January 2016

BankPolicies.com is providing you with these product updates as a courtesy to all of our clients. If you have any questions, please contact us.

Revised Policy Templates

Bank Secrecy Act Policy Template – Comprehensive Version

The update to this product is in response to the FinCEN’s Notice 2015-1 entitled “FBAR Filing Requirement – Extended Filing Date Related to Notice 2014-14” dated 12/08/15 that announced a further extension of time for certain Report of Foreign Bank and Financial Accounts (FBAR) filings in light of ongoing consideration of questions regarding the filing requirement and its application to individuals with signature authority over, but no financial interest in, certain types of accounts. FinCEN is further extending the filing due date to April 15, 2017 for individuals whose filing due date for reporting signature authority was previously extended by Notice 2014-1.


Commercial Real Estate Loan Policy Template

The update to this product is in response to the Joint Release entitled “Interagency Statement on Prudent Risk Management for Commercial Real Estate Lending” dated 12/18/15 that reminds financial institutions to implement prudent risk management practices and capital levels commensurate with the level and nature of the institution’s CRE concentration risk. In addition, the guidance provides references to existing regulations and guidance related to CRE lending, and states that the agencies, when conducting examinations that include reviews of CRE lending activities, focus on a financial institution’s adherence to guidance pertaining to the management of concentration risk and other CRE-related guidance.


Community Reinvestment Act Policy Template

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.


The update to these products is in response to the FFIEC’s Press Release entitled “Financial Regulators Release Revised Management Booklet” dated 11/10/15 that announced a revised Management booklet, which is part of the FFIEC Information Technology Examination Handbook (IT Handbook). The Management booklet, including the examination procedures, has been substantially revised. The booklet outlines the principles of sound governance and, more specifically, information technology (IT) governance. The booklet explains how IT risk management relates to enterprise-wide risk management and governance.


Regulation Z Policy Template

The update to this product is in response to the CFPB’s Final Rule entitled “2013 Integrated Mortgage Disclosures Rule Under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z)” that announced technical corrections to Regulation Z and the Official Interpretations of Regulation Z.


New and Revised Job Description Templates

Chief Information Security Officer Template – NEW!
Chief Information Technology Officer Template
Fraud Officer Template – NEW!
Loan Loss Mitigation Officer Template – NEW!

These new job description template products were developed in response to client requests. The revision to the Chief Information Technology Officer Job Description Template is in response to the FFIEC’s Press Release entitled “Financial Regulators Release Revised Management Booklet” as described above.