Product Updates March 2015

Revised Policy Templates for March 2015

Business Continuity Plan Policy Template
Vendor Management Program Policy Template

The update to these products is in response to the FFIEC’s Press Release entitled “Financial Regulators Release New Appendix to Business Continuity Planning Booklet – Appendix J: Strengthening the Resilience of Outsourced Technology Services“ dated 02/06/15 which contains guidance to assist examiners in evaluating financial institution and service provider risk management processes to ensure the availability of critical financial services. The booklet also was designed to provide guidance to financial institutions about the implementation of their business continuity planning processes.

Compliance Management Policy Template

The update to this product is in response to the CFPB’s Compliance Bulletin entitled “Existing Legal Responsibilities Regarding Treatment of Confidential Supervisory Information“ dated 01/27/15 that reminds supervised financial institutions, including nonbank companies that may be unfamiliar with federal supervision, of existing regulatory requirements regarding confidential supervisory information. The CFPB supervises companies to determine their compliance with federal consumer financial laws, to assess risks to consumers, and to help ensure a fair and transparent marketplace for consumers.

Consumer Loan Policy Template
Overdraft Policy Template

The update to these products is in response to the OCC’s Bulletin 2015-17 which announced the revised “Deposit Related Credit Booklet” dated 03/06/15. The revised booklet references relevant supervisory guidance and includes examination procedures to assess a bank’s deposit related credit products and services such as:

  • Check credit products and services;
  • Overdraft protection services;
  • Deposit advance products; and
  • Risk management of third party relationships involving these products and services.

Non-Deposit Investment Products Policy Template

The update to this product is in response to the OCC’s Bulletin 2015-2 which announced the revised “Retail Non-Deposit Investment Products Booklet” on 01/14/15. This revised booklet provides updated guidance involving the recommendation or sale of non-deposit investment products (NDIPs) to retail customers. This booklet includes an overview of bank delivery channels and the regulatory structure and requirements associated with banks offering these products. This booklet explains the risks inherent in offering such products and provides a framework for managing those risks.