Product Updates for June 2020
The Product Updates for June 2020 from BankPolicies.com feature the following new and revised policy template products:
This new product was developed in response to client requests who were contacted by their state and/or federal regulators to provide a return to work policy regarding the COVID-19 Pandemic. Your comments and ideas are always greatly appreciated and will be taken into consideration whenever we revise our current products or create new ones. In summary, we want to ensure your success and earn your business!
The update to this product is in response to FinCEN’s Advisory FIN-2020-A002 entitled “Advisory on Medical Scams Related to the Coronavirus Disease 2019 (COVID-19)” dated 05/18/20 to alert financial institutions to medical scams related to the COVID-19 pandemic. This advisory contains descriptions of COVID-19-related medical scams, case studies, red flags, and information on reporting suspicious activity.
The update to these products is in response to the Joint Release entitled “Regulators Temporarily Change the Supplementary Leverage Ratio to Increase Banking Organizations’ Ability to Support Credit to Households and Businesses in light of the Coronavirus Response” dated 05/15/20 that announced temporary changes to their supplementary leverage ratio rule. The temporary modifications will provide flexibility to certain depository institutions to expand their balance sheets in order to provide credit to households and businesses in light of the challenges arising from the coronavirus response.
The change will be effective once the rule is published in the Federal Register and will be in effect through March 31, 2021.
In addition, the Corporate Governance Policy Template was updated in response to the OCC Bulletin 2020-55 entitled “Director, Shareholder, and Member Meetings: Interim Final Rule” dated 05/26/20 that announced an interim final rule that amends 12 CFR 5 and 7 to clarify that national banks and federal savings associations (FSAs) (collectively, banks) may permit telephonic and electronic participation at all board of directors, shareholder, and, as applicable, member meetings. This interim final rule was effective on May 28, 2020.
The update to these products is in response to the SBA’s recent minor amendments to the Paycheck Protection Program (PPP), Economic Injury Disaster Loan (EIDL), and SBA Debt Relief loans.
As a reminder, the complete contents of the Small Business Administration Loan Policy Template are included as Topic 19 within the Commercial Loan Policy Template.
The update to these products is in response to the Joint Press Release entitled “Federal Agencies Share Principles for Offering Responsible Small-Dollar Loans” dated 05/20/20 that provides principles for offering small-dollar loans in a responsible manner to meet financial institutions customers’ short-term credit needs.
As a reminder, the complete contents of the Payday, Vehicle Title, and High-Cost Installment Loan Policy Template are included within the Consumer Loan Policy Template as Topic 16.
The update to these products is in response to the Joint Press Release entitled “Federal Financial Regulatory Agencies Issue Interagency Policy Statement on Allowances for Credit Losses and Interagency Guidance on Credit Risk Review Systems” dated 05/08/20 that announced a policy statement on allowances for credit losses. The statement promotes consistency in the interpretation and application of the Financial Accounting Standards Board’s credit losses accounting standard, which introduces the current expected credit losses (CECL) methodology.
The interagency policy statement describes the measurement of expected credit losses using the CECL methodology and updates concepts and practices detailed in existing supervisory guidance that remain applicable.
The Federal Reserve Board, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency issued the interagency policy statement, which will be effective at the time of each institution’s adoption of the credit losses accounting standard.
The agencies also finalized interagency guidance on credit risk review systems. The guidance presents principles for establishing a system of independent, ongoing credit risk review in accordance with safety and soundness standards.
The update to this product is in response to the CFPB’s Press Release entitled “Consumer Financial Protection Bureau Issues Final Remittance Rule” dated 05/11/20 that issued a final rule covering remittances transfers. The Remittance Rule imposes requirements on entities that send international money transfers, or remittance transfers, on behalf of consumers. Among its requirements, the rule mandates that remittance transfer providers generally must disclose the exact exchange rate, the amount of certain fees, and the amount expected to be delivered to the recipient. The rule also allows for depository institutions to estimate certain fees and exchange rate information under certain circumstances, but by statute, this provision expires in July 2020. The final rule is effective July 21, 2020.
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