Product Updates July 2015 is providing you with these product updates as a courtesy to all of our clients. If you have any questions, please contact us.

Revised Policy Templates

Flood Disaster Protection Act Policy Template

The update to this product is in response to the Joint Release entitled “Agencies Issue Flood Insurance Rule” dated 06/22/15 that announced the approval of a joint final rule that modifies regulations that apply to loans secured by properties located in special flood hazard areas. The final rule implements provisions of the Homeowner Flood Insurance Affordability Act of 2014 (HFIAA) relating to the escrowing of flood insurance payments and the exemption of certain detached structures from the mandatory flood insurance purchase requirement. The final rule also implements provisions in the Biggert-Waters Flood Insurance Reform Act of 2012 (the Biggert-Waters Act) relating to the force placement of flood insurance.

Regulation D Policy Template

The update to this product is in response to the Federal Reserve Press Release dated 06/18/15 that announced the approval of a final rule amending Regulation D (Reserve Requirements of Depository Institutions) to make changes to the calculation of interest payments on excess balances maintained by depository institutions at Federal Reserve Banks. The final rule is a matter of prudent planning and has no implications for the near-term conduct of monetary policy.

New and Revised Policy Templates

These new and revised products were in response to the FFIEC’s announcement of the “Cybersecurity Assessment Tool” dated 06/30/15 to help institutions identify their risks and assess their cybersecurity preparedness. The assessment may be used by financial institutions of all sizes to perform a self-assessment and inform their risk management strategies

As a reminder, the complete contents of the Cybersecurity Policy Template are included within the Information Systems Security Policy Template within various applicable topics.

Risk Management of Products and Services Policy Template

The update to this product is in response to the CFPB’s Press Release entitled “CFPB Outlines Guiding Principles for Faster Payment Networks” dated 07/09/15 that outlines guiding principles for protecting consumers as the private sector develops new faster payment systems. These new systems are aimed at reducing “pocket-to-pocket” payment times between consumers and businesses or other entities. The CFPB wants to ensure any new payment systems are secure, transparent, accessible, and affordable to consumers. The systems should also have robust protections when it comes to fraud and error resolution.