Product Update Blog

Product Updates for July 2022

The Product Updates for July 2022 from BankPolicies.com feature the following revised policy template products:

BSA Suspicious Activity Report Notices Template

The update to this product is in response to the FinCEN Alert FIN-2022-Alert003 entitled “FinCEN and the U.S. Department of Commerce’s Bureau of Industry and Security Urge Increased Vigilance for Potential Russian and Belarusian Export Control Evasion Attempts” dated 06/28/22 that urges financial institutions to be vigilant against efforts by individuals or entities to evade BIS export controls implemented in connection with the Russian Federation’s (Russia) further invasion of Ukraine.  This joint alert provides financial institutions with an overview of BIS’s current export restrictions; a list of commodities of concern for possible export control evasion; and select transactional and behavioral red flags to assist financial institutions in identifying suspicious transactions relating to possible export control evasion.  This alert further reminds financial institutions of their Bank Secrecy Act (BSA) reporting obligations and details how suspected export control evasion activity may also be reported to BIS enforcement authorities. As a reminder, the BSA Suspicious Activity Report Notices Template is included in the purchase price of the Bank Secrecy Act Policy Template – Comprehensive Version.

Anti-Money Laundering Policy Template – Bank Version

Bank Secrecy Act Policy Template – Comprehensive Version

Customer Identification Program Policy Template

The update to these products is in response to the FinCEN’s “Statement on Bank Secrecy Act Due Diligence for Independent ATM Owners or Operators” dated 06/22/22 that provides clarity to banks on how to apply a risk-based approach to conducting customer due diligence (CDD) on independent Automated Teller Machine (ATM) owners or operators, consistent with the requirements set out in FinCEN’s 2016 CDD Rule.  Some independent ATM owners and operators have reported difficulty in obtaining and maintaining access to banking services, which jeopardizes the important financial services they provide, including to persons in underserved markets.

Bank Secrecy Act Policy Template – Comprehensive Version

Bank Security Program Policy Template

Elder Abuse and Larcenies Against Customers Policy Template

The update to these products is in response to the FinCEN Advisory FIN-2022-A002 entitled “Advisory on Elder Financial Exploitation” alerts financial institutions to the rising trend of elder financial exploitation (EFE).  EFE involves the illegal or improper use of an older adult’s funds, property, or assets, and is often perpetrated either through theft or scams.  The advisory highlights new EFE typologies and red flags since FinCEN issued its first advisory on the issue in 2011.

Fair Credit Reporting Act Policy Template

The update to this product is in response to the CFPB’s final rule entitled “Prohibition on Inclusion of Adverse Information in Consumer Reporting in Cases of Human Trafficking” dated 06/24/22 that amends Regulation V, which implements the Fair Credit Reporting Act (FCRA), to address recent legislation that assists consumers who are victims of trafficking.  This final rule establishes a method for a victim of trafficking to submit documentation to consumer reporting agencies, including information identifying any adverse item of information about the consumer that resulted from certain types of human trafficking, and prohibits the consumer reporting agencies from furnishing a consumer report containing the adverse item(s) of information.  The CFPB is taking this action as mandated by the National Defense Authorization Act for Fiscal Year 2022 to assist consumers who are victims of trafficking in building or rebuilding financial stability and personal independence.  The rule is effective July 25, 2022.

Regulation A Policy Template

The update to this product is in response to the Federal Reserve’s final rule entitled “Regulation A: Extensions of Credit by Federal Reserve Bank” dated 06/29/22 that announced final amendments to its regulations 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 Board’s primary credit rate action.

The amendments to part 201 (Regulation A) are effective June 29, 2022.  The rate changes for primary and secondary credit were applicable on June 16, 2022.

Regulation D Policy Template

The update to this product is in response to the Federal Reserve’s final rule entitled “Regulation D: Reserve Requirements of Financial Institutions” dated 06/29/22 that announced final amendments to its regulations to revise the rate of interest paid on balances (“IORB”) maintained at Federal Reserve Banks by or on behalf of eligible institutions.  The final amendments specify that IORB is 1.65 percent, a 0.75 percentage point increase from its prior level.  The amendment is intended to enhance the role of IORB in maintaining the federal funds rate in the target range established by the Federal Open Market Committee (“FOMC” or “Committee”).

The amendments to part 204 (Regulation D) are effective June 29, 2022.  The IORB rate change was applicable on June 16, 2022.

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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