New and Revised Policy Templates for July 2016
These new and revised products were developed in response to client requests and OCC Bulletin 2016-15 that announced a new Student Lending booklet to provide a standalone policy that addresses the risks in private student lending by banks and in regulatory expectations for safe and sound operations.
Business Continuity Plan Policy Template
Cybersecurity Policy Template
Incident Response and Preparedness Policy Template
Information Systems Security Policy Template
Internet Banking Policy plate
Regulation P Policy Template
The update to these products is in response to the FFIEC’s Press Release entitled “Cybersecurity of Interbank Messaging and Wholesale Payment Network” dated 06/07/16 that advises financial institutions to actively manage the risks associated with interbank messaging and wholesale payment networks, and review risk-management practices and controls related to information technology systems and wholesale payment networks, including risk assessment; authentication, authorization and access controls; monitoring and mitigation; fraud detection; and incident response.
The update to these products is in response to the Federal Reserve’s Supervisory Letter SR 16-11 entitled “Guidance for Assessing Risk Management at Supervised Institutions with Total Consolidated Assets Less than $50 Billion“ dated 06/08/16 and the FDIC’s FIL-23-2016 dated 04/05/16 that announced a new Supervisory Insights Journal publication that provides review and commentary on the Pocket Guide for Directors, which is a set of common-sense principles that describe the responsibilities and duties of a bank’s board of directors (a framework for corporate governance that applies to any financial institution).
As a reminder, the complete contents of the Enterprise Wide Risk Management Program Policy Template and the Strategic Plan Policy Template are included within the Corporate Governance Policy Template as Topics 21 and 11 respectively.
This product was revised in response to the CFPB’s Announcement dated 06/17/16 that issued a final rule which revises (as applicable) the dollar amounts for provisions implementing amendments to TILA under the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act), the Home Ownership and Equity Protection Act of 1994 (HOEPA), and the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).