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