Product Updates January 2018

Revised Policy Templates for January 2018

Bank Secrecy Act Policy Template – Comprehensive Version

The update to this product is in response to the following FinCEN Notice 2017-1 that announced 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.  As such, FinCEN is further extending the filing due date to April 15, 2019, for individuals whose filing due date for reporting signature authority was previously extended by Notice 2016-1.


Business Continuity Plan Policy Template

The update to this product is in response to the Joint Release dated 12/15/17 issued by the federal financial institutions regulatory agencies in consultation with the Conference of State Bank Supervisors, are issuing guidance to their respective examiners regarding supervisory practices to be followed when assessing the financial condition of financial institutions directly affected by a disaster that results in a Presidential declaration of a major disaster.  In addition, the guidance applies to institutions that may be located outside the area declared a major disaster, but have loans to or investments in individuals or entities located in the area declared a major disaster.


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.

As a courtesy we also revised this product to eliminate any regulatory guidance that was in effect prior to the new Home Mortgage Disclosure Act (HMDA) rules that went into effect on 01/01/18.  Please refer to the following page of our website for information regarding the inclusion of the new rules prior to this update:

12/14/17 Update


Loan Grading and Review Policy Template

The update to this product is in response to client requests who requested we incorporate automated credit scoring guidelines into the product.  Your comments and ideas are always greatly appreciated and will be taken into consideration whenever we revise our current products or create new ones.  In summary, we want to ensure your success and earn your continued business!


Non-Accrual and Charged-Off Loan Policy Template
Other Real Estate Owned Policy Template
Risk Management of Foreclosure Policy Template
Risk Management of Subprime Mortgage Lending Policy Template
Servicemembers Civil Relief Act Policy Template
Troubled Debt Restructuring and Loan Workout Program Policy Template

These products were revised in response to the “National Defense Authorization Act for Fiscal Year 2018” that was signed into law on 12/12/17.  The act extends for two years, until December 31, 2019, the “sunset” on the temporary change of “90 days” in § 303(b) and (c) of the Servicemembers Civil Relief Act (50 U.S.C. § 3953) to “one year.”  As such, servicemembers remain entitled to the protections in § 303 during periods of active duty and for one year thereafter.


Regulation A Policy Template

The update to this product is in response to the Federal Reserve’s Final Rule issued on 12/20/17 that adopted final amendments to its Regulation A 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.


Regulation C (HMDA) Policy Template

As a courtesy we revised this product and the Regulation C Data Collection Form Template to eliminate any regulatory guidance that was in effect prior to the new Home Mortgage Disclosure Act (HMDA) rules that went into effect on 01/01/18.  Please refer to the following pages of our website for information regarding the inclusion of the new rules prior to this update:

09/05/17 Update
11/05/15 Update


Regulation D Policy Template

The update to this product is in response to the Federal Reserve’s Final Rule issued on 12/20/17 that revises 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.  The final amendments specify that IORR is 1.50 percent and IOER is 1.50 percent, a 0.25 percentage point increase from their prior levels.