Product Updates June 2021

Product Update Blog

Product Updates for June 2021

The Product Updates for June 2021 from BankPolicies.com feature the following revised policy template products:

Credit Card Policy Template

The update to this product is in response to the OCC Bulletin 2021-22 entitled “Credit Card Lending: Revised Comptroller’s Handbook Booklet” dated 04/29/21 that announced a revised “Credit Card Lending” booklet of the Comptroller’s Handbook.  The revised booklet replaces version 1.2 of the “Credit Card Lending” booklet published on January 6, 2017.  This bulletin rescinds OCC Bulletin 2015-41, “Credit Card Lending: Revised Comptroller’s Handbook Booklet and Rescissions,” which was issued on November 4, 2015.

The revised booklet:

  • Reflects the adoption of the current expected credit loss methodology by some banks and the increased use of models in credit card originations and risk management.
  • Reflects changes to OCC issuances published and rescinded since this booklet was last issued.
  • Includes clarifying edits regarding supervisory guidance, sound risk management practices, or legal language.
  • Revises certain content for general clarity.

Regulation D Policy Template

The update to this product is in response to the Federal Reserve’s Press Release entitled “Federal Reserve Board Issues Final Rule Amending Regulation D with Regard to Interest on Reserve Balances” dated 06/02/21 that announced a final rule amending Regulation D to eliminate references to an interest on required reserves (IORR) rate and to an interest on excess reserves (IOER) rate and replace them with a single interest on reserve balances (IORB) rate.  The final rule also simplifies the formula used to calculate the amount of interest to be paid on such balances and makes other minor conforming amendments.  The final rule adopts the rule proposed by the Federal Reserve Board on January 8, 2021 without change, and takes effect on Thursday, July 29, 2021.

Regulation O and Insider Activity Policy Template

The update to this product is in response to the Federal Reserve’s Press Release entitled “Federal Reserve Board Announces the Third Extension of a Rule to Bolster the Effectiveness of the Small Business Administration’s Paycheck Protection Program (PPP)” dated 05/17/21 that announced the third extension of a rule to bolster the effectiveness of the Small Business Administration’s (SBA) Paycheck Protection Program (PPP).  Like the earlier extensions, this one will temporarily modify the Federal Reserve Board’s rules so that certain bank directors and shareholders can apply to their banks for PPP loans for their small businesses.  The rule extension, which is effective immediately, applies to PPP loans made from March 31 through June 30, 2021.  The rule change will continue to apply if the PPP is extended, with the change ultimately sunsetting on March 31, 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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