Product Updates January 2025
The Product Updates for January 2025 from BankPolicies.com feature the following revised policy and form template products:
BSA Suspicious Activity Report Notices Template
The update to this product is in response to FinCEN Alert FIN-2024-Alert005 entitled “FinCEN Alert on Fraud Schemes Abusing FinCEN’s Name, Insignia, and Authorities for Financial Gain” dated 12/18/24 to raise awareness of fraud schemes abusing FinCEN’s name, insignia, and authorities for financial gain. These FinCEN-specific fraud schemes include:
- Scams that exploit beneficial ownership information (BOI) reporting;
- Misuse of FinCEN’s Money Services Business (MSB) Registration tool; or
- Involve the impersonation of, or misrepresent affiliation with, FinCEN and its employees.
These schemes are the latest evolution of scams impacting FinCEN and its stakeholders.
As a reminder, the BSA Suspicious Activity Report Notices Template is included in the purchase price of the Bank Secrecy Act Policy Template – Comprehensive Version.
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 “Announcement of 2025 Asset-Size Thresholds” dated 12/19/24 and OCC Bulletin 2024-36 entitled “Community Reinvestment Act: Revision of Small and Intermediate Small Bank and Savings Association Asset Thresholds” dated 12/23/24 that establishes for 2025 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). These asset-size thresholds are in effect from January 1, 2025, through December 31, 2025.
Corporate Governance Policy Template
Management Succession Plan Policy Template
The update to these products is in response to the NCUA’s final rule entitled “Succession Planning” dated 12/18/24 to further strengthen succession planning efforts for all consumer federally insured credit unions (FICUs). This final rule requires that a FICU board of directors establish a written succession plan that addresses specified positions and contains certain information. In addition, the board of directors is required to regularly review the succession plan. The final rule also requires that newly appointed members of the board of directors have a working familiarity with the succession plan no later than six months after appointment. The final rule is effective January 1, 2026.
The update to these products is in response to the CFPB’s final rule entitled “Overdraft Lending: Very Large Financial Institutions” dated 12/12/24 that amends Regulations E and Z to update regulatory exceptions for overdraft credit provided by very large financial institutions, thereby ensuring that these extensions of overdraft credit adhere to consumer protections required of similarly situated products, unless the overdraft fee is a small amount that only recovers estimated costs and losses. The rule allows consumers to better comparison shop across credit products and provides substantive protections that apply to other consumer credit. The final rule is effective October 1, 2025.
The update to this product is in response to the CFPB’s final rule entitled “Residential Property Assess Clean Energy Financing (Regulation Z)” dated 12/17/24 that prescribe ability-to-repay rules for Property Assessed Clean Energy (PACE) financing and to apply the civil liability provisions of the Truth in Lending Act (TILA) for violations. PACE financing is financing to cover the costs of home improvements that results in a tax assessment on the real property of the consumer. In this final rule, the CFPB implements EGRRCPA section 307 and amends Regulation Z to address how TILA applies to PACE transactions. The final rule is effective March 1, 2026.
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