Product Updates July 2025
The Product Updates for July 2025 from BankPolicies.com feature the following revised policy template products:
Bank Secrecy Act Policy Template – Comprehensive Version
Customer Identification Program Policy Template
The update to these products is in response to FinCEN’s press release entitled “FinCEN Permits Banks to Use Alternative Method for Obtaining TIN Information” dated 06/27/25 which issues an order that permits banks to collect Tax Identification Number (TIN) information from a third-party rather than from the bank’s customer. This order takes into account public comments received in response to an interagency request for information.
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); Extension of Compliance Dates” dated 06/18/25 that extends the compliance dates set forth in its 2023 small business lending rule, as amended by a 2024 interim final rule, and to make other date-related conforming adjustments. This interim final rule is effective July 18, 2025.
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