Product Updates January 2022

Product Update Blog

Product Updates for January 2022

The Product Updates for January 2022 from feature the following revised policy template products:

Business Continuity Management Policy Template

The update to this product is in response to the Joint Press Release entitled “Federal and State Financial Regulatory Agencies Issue Interagency Statement on Supervisory Practices Regarding Financial Institutions Affected by Tornados” dated 12/15/21 that stated the agencies recognize the serious impact of tornadoes on the customers and operations of many financial institutions, and will provide appropriate regulatory assistance to affected institutions subject to their supervision.  The agencies encourage institutions operating in the affected areas to meet the financial services needs of their communities.

Capital Planning Program Policy Template

Corporate Governance Policy Template

The update to these products is in response to the “Interagency Statement on the Community Bank Leverage Ratio Framework” dated 12/21/21 that issued a statement to provide information on the use of the two-quarter grace period under the optional community bank leverage ratio framework.  The community bank leverage ratio framework provides qualifying community banking organizations the option to calculate only a simple leverage ratio, rather than both risk-based and leverage-based measures of capital adequacy.  Following the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the agencies temporarily lowered the framework’s community bank leverage ratio requirement to better allow community banking organizations to support households and businesses during the COVID-19 pandemic.

Community Reinvestment Act Policy Template

The update to this product is in response to the Joint Release entitled “Agencies Release Annual CRA Asset-Size Threshold Adjustments for Small and Intermediate Small Institutions” dated 12/16/21 that announced the annual adjustment to the asset-size thresholds used to define small bank and intermediate small bank under the Community Reinvestment Act (CRA) regulations for the FDIC and Federal Reserve.  These asset-size threshold adjustments are effective January 1, 2022.

Other Real Estate Owned Policy Template

The update to this product is in response to the OCC Bulletin 2021-65 entitled “Other Real Estate Owned – Updated Comptroller’s Handbook Booklet and Rescissions” dated 12/20/21 that announced an updated “Other Real Estate Owned” booklet of the Comptroller’s Handbook.   The updated booklet replaces the booklet of the same title issued in September 2020.  Also rescinded is OCC Bulletin 2020-79, “Other Real Estate Owned: Updated Comptroller’s Handbook Booklet.”

Regulation Z Policy Template

The update to this product is in response to the CFPB’s Final Rule entitled “LIBOR Index Transition” dated 12/08/21 that issued the LIBOR Transition Rule, which amends Regulation Z to facilitate the LIBOR transition.  The LIBOR Transition Rule is generally effective April 1, 2022, although compliance with some provisions is not required until later dates.

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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