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Product Updates July 2018

Product Updates for July 2018

The Product Updates for July 2018 from BankPolicies.com feature the following revised policy template products:

Bank Secrecy Act Policy Template – Basic Version
Bank Secrecy Act Policy Template – Comprehensive Version

The update to these products is in response to FinCEN Advisory FIN-2018-A003 entitled “Advisory on Human Rights Abuses Enabled by Corrupt Senior Foreign Political Figures and their Financial Facilitators” dated 06/12/18 that highlights the connection between corrupt senior foreign political figures and their enabling of human rights abuses.  The use of financial facilitators is one way that corrupt senior foreign political figures access the U.S. and international financial systems to move or hide illicit proceeds and evade U.S. and global sanctions.  These corrupt senior foreign political figures and facilitators often contribute directly or indirectly to human rights abuses, which have a devastating impact on individual citizens, societies, and economic development.


Investment Policy Template

The update to this product is in response to the Joint Release entitled “Agencies Issue Final Rulemaking to Shorten Settlement Cycle” dated 06/01/18 that announced a final rule issued by the FDIC and OCC to shorten the standard settlement cycle for securities purchased or sold by OCC-supervised and FDIC-supervised institutions.  The final rule will require banks to settle most securities transactions within the number of business days in the standard settlement cycle followed by registered broker dealers in the United States unless otherwise agreed to by the parties at the time of the transaction.  In doing so, the rule aligns the settlement cycle requirements of the OCC, FDIC, and Board of Governors of the Federal Reserve System.


Mortgage Loan Policy Template
Non-Accrual and Charged-Off Loan Policy Template
Other Real Estate Owned Policy Template
Risk Management of Foreclosure Policy Template

The update to these products is in response to the Federal Reserve’s Consumer Affairs Letter CA 18-4 dated 06/22/18 that provides background information about the recently restored Protecting Tenants at Foreclosure Act of 2009, which became effective on June 23, 2018.  The law protects tenants from immediate eviction by persons or entities that become owners of residential property through the foreclosure process and extends additional protections for tenants with U.S. Department of Housing and Urban Development Section 8 vouchers.  The law is self-executing, and no federal agency has authority to issue regulations implementing the law or to interpret the law.


Regulation A Policy Template

The update to this product is in response to the Federal Reserve’s Final Rule issued on 06/20/18 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.


Regulation CC Policy Template

As a courtesy we revised this product to eliminate any regulatory guidance that was in effect prior to the final amendments that went into effect July 1, 2018 to the check collection and return provisions in Regulation CC (Availability of Funds and Collection of Checks).  Please refer to the following page of our website for information relating to the final amendments of Regulation CC issued on 05/31/17:

07/05/17 Update


Regulation D Policy Template

The update to this product is in response to the Federal Reserve’s Final Rule issued on 06/20/18 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 1.95 percent and IOER is 1.95 percent, a 0.20 percentage point increase from their prior levels.