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Product Update Blog

Product Updates July 2020

Product Updates for July 2020

The Product Updates for July 2020 from BankPolicies.com feature the following revised policy template products:

Bank Secrecy Act Policy Template – Basic Version

Bank Secrecy Act Policy Template – Comprehensive Version

Marijuana and Hemp-Related Policy Template

The update to these products is in response to FinCEN’s Advisory FIN-2020-G001 entitled “FinCEN Guidance Regarding Due Diligence Requirements Under the Bank Secrecy Act for Hemp-Related Business Customers” dated 06/29/20 to address questions related to Bank Secrecy Act/Anti-Money Laundering (BSA/AML) regulatory requirements for hemp-related business customers.  This guidance explains how financial institutions can conduct due diligence for hemp-related businesses, and identifies the type of information and documentation financial institutions can collect from hemp-related businesses to comply with BSA regulatory requirements.  This clarification is intended to enhance the availability of financial services for, and the financial transparency of, hemp-related businesses in compliance with federal law.  This guidance supplements the December 3, 2019 interagency statement on providing financial services to customers engaged in hemp-related businesses (December Hemp Statement).

In addition, the update to the BSA Policy Templates is in response to FinCEN’s Advisory FIN-2020-A003 entitled “Advisory on Imposter Scams and Money Mule Schemes Related to Coronavirus Disease 2019 (COVID-19)” dated 07/07/20 to alert financial institutions to potential indicators of imposter scams and money mule schemes, which are two forms of consumer fraud observed during the COVID-19 pandemic.  Many illicit actors are engaged in fraudulent schemes that exploit vulnerabilities created by the pandemic.  This advisory contains descriptions of imposter scams and money mule schemes, financial red flag indicators for both, and information on reporting suspicious activity.

As a reminder, the complete contents of the Marijuana and Hemp-Related Business Policy Template are included within topic 8 of the Bank Secrecy Act Policy Template – Comprehensive Version.

Business Continuity Management Policy Template

Pandemic Influenza Preparedness Policy Template

The update to these products is in response to the Joint Press Release entitled “Federal and State Regulatory Agencies Issue Examiner Guidance for Assessing Safety and Soundness Considering the Effect of COVID-19 Pandemic on Financial Institutions” dated 06/23/20 that issued examiner guidance to promote consistency and flexibility in the supervision and examination of financial institutions affected by the COVID-19 pandemic.  The interagency guidance instructs examiners to consider the unique, evolving, and potentially long-term nature of the issues confronting institutions due to the COVID-19 pandemic and to exercise appropriate flexibility in their supervisory response.

As a reminder, the complete contents of the Pandemic Influenza Preparedness Policy Template are included as topic 18 within the Business Continuity Management Policy Template.

Community Reinvestment Act Policy Template

The update to this product is in response to the OCC’s News Release 2020-63 entitled “OCC Finalizes Rule to Strengthen and Modernize Community Reinvestment Act Regulations” dated 05/20/20 that released a final rule strengthening and modernizing the agency’s regulations under the Community Reinvestment Act (CRA).  The final rule, which was made without the FDIC and Federal Reserve, will increase bank CRA-related lending, investment, and services in low- and moderate-income communities where there is significant need for credit, more responsible lending, and greater access to banking services.

The final rule is effective on October 1, 2020, and banks must comply with the final amendments by October 1,2020, January 1, 2023, or January 1, 2024, as applicable.  Until the compliance dates, banks must continue to comply with parts 25 and 195 that are in effect on September 30, 2020 as set forth in appendix C to 12 CFR 25.  Alternatively, the OCC may permit a bank to voluntarily comply, in whole or in part, with the amendments adopted in this release prior to the applicable compliance dates.  Parts 25 and 195 that are in effect on September 30, 2020 (as set forth in appendix C) expire on January 1, 2024.

NOTE:  Since the final rule has multiple compliance dates and variables, clients who order this product or are covered by a Product Update Protection Plan will receive two versions (current and future) to ensure complete coverage of existing and future rules.  Going forward, we anticipate that the FDIC and Federal Reserve will release their updated CRA final rules that should be somewhat similar in the near future.

Mortgage Servicing Policy Template

Regulation X Policy Template

The update to these products is in response to the CFPB’s News Release entitled “CFPB Issues Interim Final Rule on Loss Mitigation Options for Homeowners Recovering from Pandemic-Related Financial Hardships” dated 06/23/20 that announced an interim final rule (IFR) that will make it easier for consumers to transition out of financial hardship caused by the COVID-19 pandemic and easier for mortgage servicers to assist those consumers.  The interim final rule is effective 07/01/20.

As a reminder, the complete contents of the Mortgage Loan Servicing Policy Template are included as Topic 18 within the Regulation X Policy Template.

Regulation C Policy Template

As a courtesy, we revised this product to eliminate any regulatory guidance that was in effect prior to the new Home Mortgage Disclosure Act (HMDA) rule that went into effect on 07/01/20.

Regulation CC Policy Template

As a courtesy, we revised this product to eliminate any regulatory guidance that was in effect prior to the new amendments to Regulation CC that went into effect on 07/01/20.

Regulation E Policy Template

As a courtesy we revised this product to eliminate any regulatory guidance that was in effect prior to the new amendments to Regulation E that are effective 07/21/20.

Keeping You Informed

We provide this Product Update Blog as a courtesy to all clients regarding new and revised products released by BankPolicies.com.  We feel that it is important to keep our clients well informed of changes to the financial institution industry, including keeping on top of federal regulatory changes, and industry recommended best practices.  In this regard, we encourage you to subscribe to our newsletter in which these types of announcements are made including any special offers that can save you time and money.  Just contact us to be added to our distribution list.

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