New Job Description Templates and Revised Policy Templates for March 2018
These new products were developed in response to client requests who submitted their suggestions to our “Client Wish List.” 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 these products is in response to the OCC’s Bulletin 2018-4 entitled “Final Rule – Testing and Conforming Changes” dated 02/23/18 that announced a final rule to implement several technical and conforming changes to the OCC’s Annual Stress Test regulation (12 CFR 46). The final rule changes the range of possible “as-of” dates used in the global market shock component to conform to changes recently made by the Board of Governors of the Federal Reserve System to its stress testing regulations. The final rule also changes the transition period for an institution that becomes an over $50 billion covered institution. Finally, the final rule makes certain technical changes to clarify the requirements of the OCC’s stress testing regulation.
The final rule:
- Extends the range of possible “as-of” dates used in the trading and counterparty default component of the annual stress tests by three months. The previous rule stated that the as-of date may occur between January 1 and March 1 of the calendar year of the stress test. The final rule extends this window to incorporate the prior three months, so that the new window would be October 1 through March 1.
- Extends the transition process for certain covered national banks and federal savings associations that cross the $50 billion asset threshold.
- Makes technical and linguistic changes to the OCC’s stress testing regulation in order to promote clarity. The final rule removes certain obsolete transition provisions. The final rule also changes the defined term “over $50 billion covered institution” to “$50 billion or over covered institution” to be more precise.