Product Updates January 2026
The Product Updates for January 2026 from BankPolicies.com feature the following revised policy template products:
Commercial Loan Policy Template
Leveraged Financing Policy Template
The update to these products is in response to the Interagency Statement entitled “Leveraged Lending: Interagency Statement on Rescission of Interagency Leveraged Lending Guidance Issuances” dated 12/05/25 that announced that the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) are withdrawing from the “Interagency Guidance on Leveraged Lending” (2013 Guidance), dated March 21, 2013, and the “Frequently Asked Questions for Implementing March 2013 Interagency Guidance on Leveraged Lending” (2014 FAQs), dated November 7, 2014. The OCC and FDIC expect banks to manage leveraged lending exposures consistent with general principles for safe and sound lending, and are also rescinding their communications that transmitted these two documents.
Commercial Loan Policy Template
The update to these products is in response to the OCC Bulletin 2025-45 entitled “Commercial Lending: Venture Loans to Companies in an Early, Expansion, or Late Stage of Corporate Development” dated 12/05/25 that updates guidance that applies to commercial loans to companies in an early, expansion, or late stage of corporate development (commonly referred to as “venture loans”). This updated bulletin provides transparency into the OCC’s supervisory approach and application of existing laws, regulations, and guidance. Specifically, the updated guidance reflects the OCC’s policy of not discouraging banks from engaging in prudent venture lending activities. Instead, it is the responsibility of the bank’s board and management to ensure that venture loans are consistent with the bank’s risk appetite, maintained within established risk limits, appropriately documented and underwritten, accurately risk-rated, and sufficiently reserved. Given the heightened uncertainty and higher probability of failure associated with new business ventures, venture loans tend to have a higher risk of default than other commercial loans, which should be reflected in banks’ risk management practices.
This bulletin rescinds OCC Bulletin 2023-34, “Commercial Lending: Venture Loans to Companies in an Early, Expansion, or Late State of Corporate Development.”
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 2026 Asset-Size Thresholds” dated 12/30/25 and OCC Bulletin 2025-48 entitled “Community Reinvestment Act: Revision of Small and Intermediate Small Bank and Savings Association Asset Thresholds” dated 12/23/25 that establishes for 2026 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, 2026, through December 31, 2026.
Cryptocurrency Policy Template
The update to this product is in response to OCC Interpretive Letter #1188 entitled “National Banks Engagement in Riskless Principal Transactions in Crypto-Assets” dated 12/09/25 that confirms that a national bank may engage in riskless principal crypto-asset transactions as part of the business of banking. Such transactions involve a bank acting as principal in a crypto-asset transaction with one customer while simultaneously entering into an offsetting transaction with another customer. The bank serves as an intermediary and does not hold the crypto-assets in inventory, instead acting in a capacity equivalent to that of a broker acting as agent.
As with any activity, a national bank must conduct these activities in a safe and sound manner and in compliance with applicable law.
The update to this product is in response to the Federal Reserve’s Final Rule entitled “Regulation A: Extensions of Credit by Federal Reserve Banks” dated 12/19/25 that announced final amendments to its regulations to reflect the Federal Reserve Board’s approval of a decrease in the rate for primary credit at each Federal Reserve Bank. The secondary credit rate at each Reserve Bank automatically decreased by formula as a result of the Board’s primary credit rate action.
The amendments to part 201 (Regulation A) are effective 12/19/25. The rate changes for primary and secondary credit were applicable on 12/11/25.
The update to this product is in response to the Federal Reserve’s Final Rule entitled “Regulation D: Reserve Requirements of Financial Institutions” dated 12/19/25 that announced final amendments to its regulations to revise the rate of interest paid on balances (“IORB”) maintained at Federal Reserve Banks by or on behalf of eligible institutions. The final amendments specify that IORB is 3.65 percent, a 0.25 percentage point decrease from its prior level. The amendment is intended to enhance the role of IORB in maintaining the federal funds rate in the target range established by the Federal Open Market Committee (“FOMC” or “Committee”).
The amendments to part 204 (Regulation D) are effective 12/19/25. The IORB rate change was applicable on 12/11/25.
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