Product Updates for July 2019
The Product Updates for July 2019 from BankPolicies.com feature the following revised policy template products:
The update to these products is in response to OFAC’s “Amendment of the Reporting, Procedures, and Penalties Regulations (RPPR)” dated 06/20/19 that sets forth standard reporting and recordkeeping requirements and license application and other procedures relevant to the economic sanctions programs administered by OFAC which took effect upon publication in the Federal Register on 06/21/19.
This rule provides updated instructions and incorporates new requirements for parties filing reports on blocked property, unblocked property, or rejected transactions; revises the licensing procedures section to include information regarding OFAC’s electronic license application procedures, and to provide additional instructions regarding applications for the release of blocked funds; and clarifies the rules governing the availability of information under federal law, including the Freedom of Information Act (FOIA), for information that is submitted to OFAC in connection with blocking or unblocking reports, reports on rejected transactions, or license applications.
As a reminder, the complete contents of the Office of Foreign Assets Control Policy Template are included within the Bank Secrecy Act Policy Template – Comprehensive Version as Topic 19.
The update to these products is in response to the CFPB’s final rule entitled “Payday, Vehicle Title, and Certain High-Cost Installment Loans; Delay of Compliance Date; Correcting Amendments” dated 06/06/19 that delays the August 19, 2019 compliance date for the mandatory underwriting provisions of the regulation promulgated by the CFPB in November 2017 governing Payday, Vehicle Title, and Certain High-Cost Installment Loans (2017 Final Rule or Rule). Compliance with these provisions of the Rule is delayed by 15 months, to November 19, 2020. In addition, the CFPB is making certain corrections to address several clerical and non-substantive errors it has identified in other aspects of the rule.
As a reminder, the complete contents of the Payday, Vehicle Title, and High-Cost Installment Loan Policy Template are included within the Consumer Loan Policy Template as Topic 16.
As a courtesy we revised this product to eliminate the phase “EFFECTIVE JULY 1, 2019…” within the template in relation to this final rule that went into effect on that day.
The update to this product is in response to the OCC Bulletin 2019-28 entitled “Risk Management Guidance for Higher-Loan-to-Value Lending Activities in Communities Targeted for Revitalization” dated 06/19/19 that encourages banks to continue to develop responsible, innovative lending strategies intended to meet the credit needs of individual borrowers and support revitalization efforts. These efforts could include residential mortgage lending products for the purchase, refinancing, or rehabilitation of owner-occupied one- to four-family properties, where the loan-to-value (LTV) ratio at the time of origination exceeds 90%, and the loan is without mortgage insurance, readily marketable collateral, or other acceptable collateral (higher-LTV loans). Higher-LTV loans should be consistent with safe and sound lending practices, promote fair access to credit and fair treatment of borrowers, and comply with applicable laws, rules and regulations.
Keeping You Informed
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