Product Updates January 2024

Product Update Blog

Product Updates for January 2024

The Product Updates for January 2024 from feature the following new and revised policy template products:

Bank Secrecy Act Policy Template – Comprehensive Version

The update to this product is in response to FinCEN Notice FIN-2023-NTC5 entitled “FBAR Filing Requirement for Certain Financial Professionals: Extended Filing Date Related to Notice 2022-1” dated 12/20/23 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 16, 2016, which proposes to revise the regulations implementing the Bank Secrecy Act (BSA) regarding FBARs.

Commercial Real Estate Loan Policy Template

Concentrations of Credit Policy Template

The update to these products is in response to FDIC FIL-64-2023 entitled “Advisory: Managing Commercial Real Estate Loan Concentrations in a Challenging Economic Environment” dated 12/18/23 that:

  • Reemphasizes the importance of strong capital, appropriate credit loss allowance levels, and robust credit risk-management practices for institutions with commercial real estate (CRE) concentrations;
  • Conveys several key risk management practices for institutions to consider in managing CRE loan concentrations in the current challenging economic environment; and
  • Reemphasizes the importance of effectively managing liquidity and funding risks, which can compound lending risks, particularly for CRE-concentrated institutions.

This advisory replaces the 2008 advisory: Managing Commercial Real Estate Concentrations in a Challenging Environment (issued March 17, 2008).

Community Reinvestment Act Policy Template

The update to this product is in response to the Joint Release by the FDIC and the Federal Reserve entitled “Joint Final Rule: Technical Amendment” dated 12/20/23 and OCC Bulletin 2023-40 entitled “Community Reinvestment Act: Revision of Small and Intermediate Small Bank and Savings Association Asset Thresholds” dated 12/26/23 that establishes for 2024 the asset-size thresholds used to define “small bank or savings association” and “intermediate small bank or savings association” in their Community Reinvestment Act regulations.  As required, the adjustment to the threshold amounts are based on the annual percentage change in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI–W).  The effective date is January 1, 2024.

FDIC Advertising Policy TemplateNEW!

Marketing Plan and Program Policy Template

These new and revised products are in response to FDIC FIL-65-2023 entitled “FDIC Official Signs and Advertising Requirements, False Advertising, Misrepresentations of Insured Status, and Misuse of the FDIC’s Name or Logo” dated 12/20/23 that announced a final rule to amend part 328 of its regulations to modernize the rules governing use of the official FDIC sign and insured depository institutions’ (IDIs’) advertising statements to reflect how depositors do business with IDIs today, including through digital and mobile channels.  The final rule also clarifies the FDIC’s regulations regarding misrepresentations of deposit insurance coverage, which apply to any person, including IDIs and non–bank entities.  The final rule addresses specific scenarios where consumers may be misled as to whether they are conducting business with an IDI and whether their funds are protected by federal deposit insurance.  The final rule extends the certainty and confidence the FDIC official sign has consistently provided since the 1930s at traditional IDI branch teller windows to the evolving digital banking channels through which depositors increasingly handle their banking needs today.

The amendments made by the final rule will take effect on April 1, 2024 with an extended compliance date of January 1, 2025.

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.

Shopping Cart
Scroll to Top