Revised Policy Templates for July 2017
The update to this product is in response to the “Interagency Advisory on the Availability of Appraisers” dated 05/31/17 that announced guidance for insured depository institutions and bank holding companies (collectively, regulated institutions) of two existing options that may address appraiser shortages, particularly in rural areas: temporary practice permits and temporary waivers.
The update to this product is in response to NACHA’s “Third-Party Sender Registration Rule” which requires Originating Depository Financial Institutions (ODFIs) to identify and register their third-party sender customers in order to promote consistent customer due diligence among all ODFIs, and serve as a tool to support NACHA’s continuing efforts to maintain ACH Network quality. The rule is effective 09/29/17.
The update to these products is in response to the FDIC’s Press Release entitled “FDIC Consumer News Issues Warning About 10 Scams Targeting Bank Customers” issued on 06/12/17 that alerts financial institutions and the general public to common scams and provides basic tips for protecting personal information and money.
As a reminder, the complete contents of the Elder Abuse and Larcenies Against Customers Policy Template are include as topic 12 within the Bank Security Program Policy Template.
The update to this product is in response to OCC Bulletin 2017-22 entitled “Shortening the Settlement Cycle” dated 06/09/17 that highlight actions that financial institutions should take to prepare for the change in the regular securities settlement cycle for most U.S. securities transactions. The change becomes effective on September 5, 2017.
The update to this product is in response to the FDIC’s FIL-22-2017 entitled “Adoption of Supervisory Guidance on Model Risk Management” dated 06/07/17 that addresses supervisory expectations for model risk management, including: model development, implementation, and use; model validation; and governance, policies, and controls.
The update to this product is in response to the Federal Reserve’s Final Rule issued on 06/26/17 that adopted final amendments to its Regulation A to reflect the Federal Reserve Board’s approval of an increase in the rate for primary credit at each Federal Reserve Bank. The secondary credit rate at each Reserve Bank automatically increased by formula as a result of the Federal Reserve Board’s primary credit rate action.
The update to this product is in response to the Federal Reserve’s Final Rule issued on 06/26/17 that revises the rate of interest paid on balances maintained to satisfy reserve balance requirements (“IORR”) and the rate of interest paid on excess balances (“IOER”) maintained at Federal Reserve Banks by or on behalf of eligible institutions. The final amendments specify that IORR is 1.25 percent and IOER is 1.25 percent, a 0.25 percentage point increase from their prior levels.
The update to this product is in response to the Federal Reserve’s Press Release dated 05/31/17 that announced final amendments to the check collection and return provisions in Regulation CC (Availability of Funds and Collection of Checks) and also requested further public comment on an additional proposed amendment to Regulation CC’s liability provisions. The final amendments become effective July 1, 2018.
The update to this product is in response to the OCC’s Bulletin 2017-21 entitled “Frequently Asked Questions to Supplement OCC Bulletin 2013-29” dated 06/07/17 that addresses frequently asked questions posed by financial institutions regarding third party relationships in relation to vendor management regulatory guidelines.
In addition, the following products were revised to reflect the use of SSAE 18 reports which replaced SSAE 16 for SOC 1 engagements effective May 2017:
Audit Policy Template
Business Continuity Plan Policy Template
Cloud Computing Policy Template
Consumer Loan Policy Template
Information Systems Security Policy Template
Internet Banking Policy Template
Managed Security Service Providers Policy Template
Merchant Services Program Policy Template
Mobile Banking Policy Template
Overdraft Policy Template
Remote Deposit Capture Program Policy Template
Student Loan Policy Template