Product Updates for June 2018
The Product Updates for June 2018 from BankPolicies.com feature the following revised policy template products:
The update to these products is in response to the FFIEC’s Press Release entitled “FFIEC Issues New Customer Due Diligence and Beneficial Ownership Examination Procedures” dated 05/11/18 that announced new examination procedures on the final rule, “Customer Due Diligence Requirements for Financial Institutions,” issued by the Financial Crimes Enforcement Network (FinCEN) on May 11, 2016. In addition, a new overview and examination procedures were developed for the beneficial ownership requirements for legal entity customers. Banks and other covered financial institutions must comply with this rule beginning on May 11, 2018.
In addition, the update to the Bank Secrecy Act Policy Template – Comprehensive Version and Customer Identification Program Policy Template is in response to FinCEN’s Administrative Ruling entitled “FIN-2018-R001 – Premium Cash Finance Refunds and Beneficial Ownership Requirements for Legal Entity Customers” dated 05/11/18 that provide exceptive relief to covered financial institutions with respect to the application of the Beneficial Ownership Requirements for Legal Entity Customers (31 CFR § 1010.230) (Beneficial Ownership Rule) to premium finance lending products that allow for cash refunds. Furthermore, the update to these products is in response to FinCEN’s Administrative Ruling entitled “FIN-2018-R002 – Beneficial Ownership Requirements for Legal Entity Customers of Certain Products and Services with Automatic Rollovers or Renewals” dated 05/16/18 that grants an exception to covered financial institutions for 90 days, up to and including August 9, 2018, from the Beneficial Ownership Rule’s requirements to identify and verify beneficial ownership information for rollover or renewal of certain financial products and services (i.e., CD and loan accounts) that were established before May 11, 2016.
As a reminder, the complete contents of the Customer Identification Program Policy Template are included within the Bank Secrecy Act Policy Template – Comprehensive Version as Topic 7.
The update to these products is in response to the CFPB’s Press Release entitled “Statement of the Bureau of Consumer Financial Protection on Enactment of S.J. Res. 57” dated 05/21/18 that announced the President signed into law a bipartisan Congressional resolution disapproving a rule that was in the form of guidance issued by the Bureau of Consumer Financial Protection (Bureau) on 03/21/13 about indirect auto lender compliance with the Equal Credit Opportunity Act (ECOA) and its implementing regulation.
The update to this product is in response to the Federal Reserve’s Final Rule issued on 05/07/18 that announced the approval of final amendments to its Regulation A, which governs extensions of credit by Federal Reserve Banks, to make certain technical adjustments including to reflect the expiration of the Term Asset Backed Securities Loan Facility (TALF) program. The final amendments revise the provisions regarding the establishment of the primary credit rate at the discount window in a financial emergency, and delete obsolete provisions relating to the use of credit ratings for collateral for extensions of credit under the former TALF program.
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