Product Update Blog

Product Updates for January 2019

The Product Updates for January 2019 from feature the following new and revised policy and job description template products:

Asset, Liability and Liquidity Management Policy Template
Brokered Deposits Policy Template

The update to these products is in response to the FDIC’s Press Release entitled “FDIC Issues Final Rule on Reciprocal Deposits and Seeks Comments on Brokered Deposits and Interest Rate Restrictions” dated 12/19/18 that announced a final rule related to the treatment of reciprocal deposits. The final rule implements Section 202 of the Economic Growth, Regulatory Relief, and Consumer Protection Act to exempt certain reciprocal deposits from being considered as brokered deposits for certain insured institutions. The final rule also makes conforming amendments to the FDIC’s regulations governing deposit insurance assessments. The final rule will take effect 30 days after publication in the Federal Register.

As a reminder, the complete contents of the Brokered Deposits Policy Template are included within the Asset, Liability and Liquidity Management Policy Template as Topic 6.

Automated Clearing House Policy Template

The update to this product is in response to the following NACHA announcements:

  • Supplementing Data Security Requirements” – This change to the NACHA Operating Rules is effective 06/30/21 and will enhance quality and improve risk management within the ACH Network by supplementing the existing account information security requirements for large-volume originators and third-parties and be implemented in two phases.
  • Expanding Same-Day ACH” – This new rule expands access to same-day ACH by allowing same-day ACH transactions to be submitted to the ACH Network for an additional two hours every business day. The new same-day ACH processing window will go into effect on 03/19/21.

Bank Secrecy Act Policy Template – Comprehensive Version

The update to this product is in response to the following FinCEN Notice 2018-1 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, 2020, for individuals whose filing due date for reporting signature authority was previously extended by Notice 2017-1.

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” dated 12/21/18 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.

Regulation C 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 01/01/19.

Community Reinvestment Act Specialist Job Description Template – NEW!
Human Resources Recruiter Job Description Template – NEW!
Incident Response Officer – NEW!

These new products were developed in response to client requests who submitted their suggestions to our “Client Wish List.”  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 business!

Keeping You Informed

We provide this Product Update Blog as a courtesy to all clients regarding new and revised products released by  We feel that it is important to keep our clients well informed of changes to the financial institution industry, including keeping on top of federal regulatory changes, and industry recommended best practices.  In this regard, we encourage you to subscribe to our newsletter in which these types of announcements are made including any special offers that can save you time and money.  Just contact us to be added to our distribution list.

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