New and Revised Policy Templates for January 2017
These new and revised products were developed in response to client requests and OCC Bulletin 2016-42 that announced a revised “Bank Premises and Equipment” booklet which provides updated guidance regarding risks and best practices associated with bank premises and equipment.
The complete contents of the new Bank Premises and Equipment Risk Management Policy Template are included within the Fixed Asset Policy Template as Topic 5.
The update to these products is in response to the CFPB’s Compliance Bulletin 2016-03 entitled “Detecting and Preventing Consumer Harm from Production Incentives“ dated 11/28/16 that compiles guidance that has previously been given by the CFPB in other contexts and highlights examples from the CFPB’s supervisory and enforcement experience in which incentives contributed to substantial consumer harm. In addition, it describes compliance management steps supervised entities should take to mitigate risks posed by incentives.
As a reminder, the complete contents of the new Human Resources Incentive Compensation Policy Template are included within the Human Resources Salary Administration Policy Template as Topic 4.
The update to these products is in response to OCC Bulletin 2016-44 that announced a revised “Consigned Items and Other Customer Services” booklet which provides updated guidance regarding risks and best practices associated with consigned items and other customer services.