Product Updates June 2024

Product Update Blog

Product Updates for June 2024

The Product Updates for June 2024 from BankPolicies.com feature the following revised policy template products:

Asset, Liability, and Liquidity Management Policy Template

The update to this product is in response to the FDIC’s revised “Risk Management Manual of Examination Policies” dated 04/29/24 that announced a revised Section 6.1 – Liquidity and Funds Management. Updates to Section 6.1 include revisions to incorporate regulatory changes related to brokered deposits; to provide additional guidance regarding uninsured deposits, Federal Home Loan Bank advances, and public funds; to add new sections on evaluating asset encumbrance and intraday liquidity monitoring; and to make other technical edits.

NOTE:  Clients who have purchased our Liquidity Contingency Funding Plan Policy Template which is covered by a Product Update Protection Plan will automatically receive the updated Asset, Liability, and Liquidity Management Policy Template as a free upgrade since we are discontinuing the Liquidity Contingency Funding Plan Policy Template.  Please rest assured that the Contingency Funding Plan is addressed as Topic 14 within the Asset, Liability, and Liquidity Management Policy Template.  In addition, your Product Update Protection Plan will be moved over to cover any future updates we issue to the more comprehensive Asset, Liability, and Liquidity Management Policy Template.

BSA Suspicious Activity Report Notices Template

The update to this product is in response to FinCEN Advisory FIN-2024-A001 entitled “FinCEN Advisory to Financial Institutions to Counter the Financing of Iran-Backed Terrorist Organizations” dated 05/08/24 to assist financial institutions in detecting potentially illicit transactions related to Islamic Republic of Iran (Iran)-backed terrorist organizations amid intensified terrorist activity in the Middle East.

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.

Bank Secrecy Act Policy Template – Comprehensive Version

Office of Foreign Assets Control Policy Template

The update to these products is in response to OFAC’s interim final rule entitled “Reporting, Procedures and Penalties Regulations” dated 05/08/24 that amends standard reporting and recordkeeping requirements and license application and other procedures relevant to the economic sanctions programs administered by OFAC.  This interim final rule is effective 90 days after date of publication in the Federal Register.

Regulation CC Policy Template

The update to this product is in response to the Joint Press Release entitled “Agencies Announce Inflation-Adjusted Dollar Thresholds for Regulation CC Funds Availability” dated 05/13/24 that adjusted for inflation dollar amounts relating to the availability of customer funds.  These changes in Regulation CC include the minimum amount of deposited funds that banks must make available for withdrawal by opening of business on the next day for certain check deposits as well as the amount of funds deposited by certain checks in a new account that are subject to next-day availability.

By law, the agencies are required to adjust these dollar thresholds every five years by the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W).  The inflation measurement period for this adjustment began in July 2018 and ended in July 2023.

To help ensure that depository institutions have sufficient time to implement the adjustments, the compliance date for the new amounts is July 1, 2025.

Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) Policy Template

The update to this product is in response to the CFPB’s Consumer Financial Protection Circular 2024-03 entitled “Unlawful and Unenforceable Contract Terms and Conditions” dated 06/04/24 that provides guidance regarding unlawful or unenforceable terms and conditions in contracts for consumer financial products and services that violate the prohibition on deceptive acts or practices in the Consumer Financial Protection Act (CFPA).

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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