Product Updates for July 2024
The Product Updates for July 2024 from BankPolicies.com feature the following revised policy and form template products:
Model Risk Management Program Policy Template
The update to these products is in response to the Joint Release entitled “Quality Control Standards for Automated Valuation Models” dated 06/20/24 that announces a final rule to implement the quality control standards mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) for the use of automated valuation models (AVMs) by mortgage originators and secondary market issuers in determining the collateral worth of a mortgage secured by a consumer’s principal dwelling. Under the final rule, institutions that engage in certain credit decisions or securitization determinations must adopt policies, practices, procedures, and control systems to ensure that:
- AVMs used in these transactions to determine the value of mortgage collateral adhere to quality control standards designed to ensure a high level of confidence in the estimates produced by AVMs;
- Protect against the manipulation of data;
- Seek to avoid conflicts of interest;
- Require random sample testing and reviews; and
- Comply with applicable nondiscrimination laws.
This final rule is effective the first day of the calendar quarter following 12 months after the date of publication in the Federal Register.
Automated Clearing House Policy Template
The update to this product is in response to Nacha Operations Bulletin 2024-1 entitled “Changes to Upcoming Rules Effective Dates” dated 07/01/24 that announced the effective date of recently adopted rules language requiring an RDFI to notify the ODFI of the status of a request for return within 10 banking days has been extended by 6 months to April 1, 2025.
BSA Suspicious Activity Report Notices Template
The update to this product is in response to FinCEN Advisory FIN-2024-A002 entitled “Supplemental Advisory on the Procurement of Precursor Chemicals and Manufacturing Equipment Used for the Synthesis of Illicit Fentanyl and Other Synthetic Opioids” dated 06/20/24 to highlight new trends in the illicit fentanyl supply chain since the publication of FinCEN’s 2019 Advisory on Illicit Financial Schemes and Methods Related to the Trafficking of Fentanyl and Other Synthetic Opioids (“2019 Fentanyl Advisory”), and to urge vigilance in identifying and reporting related suspicious activity. While the 2019 Fentanyl Advisory and the typologies and red flags therein remain valid, this supplemental advisory highlights how Mexico-based transnational criminal organizations (TCOs) purchase fentanyl precursor chemicals, pill presses, die molds, and other manufacturing equipment (hereafter “fentanyl precursor chemicals and manufacturing equipment”) primarily originating from companies located in the People’s Republic of China (PRC) to synthesize illicit fentanyl and other synthetic opioids in Mexico before the substances enter the illicit drug market in the United States.
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.
Non-Deposit Investment Products Policy Template
The update to this product is in response to OCC Bulletin 2024-13 entitled “Retail Non-Deposit Investment Products: Revised Comptroller’s Booklet and Rescissions” dated 06/11/24 that discusses risks and risk management practices associated with the recommendation or sale of non-deposit investment products to retail customers. The revised booklet:
- Incorporates significant regulatory changes adopted in the U.S. Securities and Exchange Commission’s Regulation Best Interest that may relate to banks’ securities activities;
- Reflects OCC and interagency issuances that have been published or rescinded since January 2015;
- Provides further clarity regarding sound risk management practices and guidance; and
- Includes other minor updates for general clarity.
The revised booklet replaces version 1.0 of the booklet with the same title issued January 2015. Also rescinded is OCC Bulletin 2015-2, “Retail Non-Deposit Investment Products: Revised Comptroller’s Handbook Booklet and Rescissions.”
The update to this product is in response to the CFPB’s Interim Final Rule entitled “Small Business Lending Under the Equal Credit Opportunity Act (Regulation B)” dated 06/26/24 that in light of court orders in ongoing litigation, the CFPB is amending Regulation B to extend the compliance dates set forth in its 2023 small business lending rule and to make other date-related conforming adjustments. This interim final rule is effective 30 days after publication in the Federal Register.
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