Product Update Blog

Product Updates for January 2023

The Product Updates for January 2023 from BankPolicies.com feature the following new and revised policy template products:

Regulation ZZ Policy TemplateNEW!

This new product was developed in response to the Federal Reserve’s Press Release entitled “Federal Reserve Board Adopts Final Rule that Implements Adjustable Interest Rate (LIBOR) Act by Identifying Benchmark Rates Based on SOFR (Secured Overnight Financing Rate) that will Replace LIBOR in Certain Financial Contracts After June 30, 2023” dated 12/26/22.   The final rule is substantially similar to the proposal with certain clarifying changes made in response to comments, and is effective 02/27/23 (30 days after publication in the Federal Register).

Cryptocurrency Policy Template

The update to this product is in response to the Joint Press Release entitled “Joint Statement on Crypto-Asset Risks to Banking Organizations” dated 01/03/23 that highlights key risks for banking organizations associated with crypto-assets and the crypto-asset sector and describing the agencies’ approaches to supervision in this area.

In particular, the statement describes several key risks associated with crypto-assets and the crypto-asset sector, as demonstrated by the significant volatility and vulnerabilities over the past year.  Given these risks, the agencies continue to take a careful and cautious approach related to current and proposed crypto-asset-related activities and exposures at banking organizations.  The agencies continue to assess whether or how current and proposed crypto-asset-related activities by banking organizations can be conducted in a manner that is safe and sound, legally permissible, and in compliance with applicable laws and regulations, including those designed to protect consumers.

Bank Secrecy Act Policy Template – Comprehensive Version

Office of Foreign Assets Control Policy Template

The update to these products is in response to the U.S. Treasury Recent Action entitled “Publication of Illicit Drug Trade Sanctions Regulations” dated 12/19/22 that added regulations to implement Executive Order 14059 of December 15, 2021, “Imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade.”  These regulations are currently available for public inspection with the Federal Register and will take effect upon publication in the Federal Register on Tuesday, December 20, 2022.  OFAC intends to supplement these regulations with a more comprehensive set of regulations, which may include additional interpretive guidance and definitions, general licenses, and other regulatory provisions.

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 12/19/22 that announced the annual adjustment to the asset-size thresholds used to define small bank and intermediate small bank.  As required by the Community Reinvestment Act (CRA) regulations, the adjustment to the threshold amount is based on the annual percentage change in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W).  The adjustments are effective January 1, 2023.

Overdraft Policy Template

The update to this product is in response to the Federal Reserve Press Release entitled “Federal Reserve Board Issues Technical Updates to its Policy Governing the Provision of Intraday Credit in Accounts at Federal Reserve Banks” dated 12/21/22.  In particular, the updates include a new rule establishing settlement times for debits and credits to institutions’ Federal Reserve accounts for certain transactions.  The updates streamline the settlement process and shorten the time needed for debits and credits to settle.  The updates are effective on January 30, 2023.

Keeping You Informed

We provide this Product Update Blog as a courtesy to all clients regarding new and revised products released by BankPolicies.com.  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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