Product Updates for March 2021
The Product Updates for March 2021 from BankPolicies.com feature the following new job description template products and revised policy template products:
Accountant Job Description Template – NEW!
Environmental Risk Officer Job Description Template – NEW!
Information Technology Architect Job Description Template – NEW!
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!
Bank Secrecy Act Policy Template – Basic Version
Bank Secrecy Act Policy Template – Comprehensive Version
Customer Identification Program Policy Template
The update to these products is in response to the announcement of new and revised sections of the FFIEC BSA/AML Examination Manual dated 01/25/21 that added a new introductory section entitled “Assessing Compliance with BSA Regulatory Requirements” and revised content in the following sections:
Customer Identification Program
Currency Transaction Reporting
Transactions of Exempt Persons
In addition, the Bank Secrecy Act Policy Templates were revised in response to the following FinCEN Advisories:
FIN-2021-A002 entitled “Advisory on Financial Crimes Targeting COVID-19 Economic Impact Payments” dated 02/24/21 to alert financial institutions to fraud and other financial crimes related to the Economic Impact Payments (EIPs), authorized by the Coronavirus Aid, Relief, and Economic Security (CARES) Act, and the Coronavirus Response and Relief Supplemental Appropriations Act of 2021.
FIN-2021-NTC2 entitled “FinCEN Informs Financial Institutions of Efforts Related to Trade in Antiquities and Art” dated 03/09/21 to inform financial institutions about the Anti-Money Laundering Act of 2020 (the AML Act) efforts related to trade in antiquities and art, select sources of information about existing illicit activity related to antiquities and art, and provide specific instructions for filing Suspicious Activity Reports (SARs) related to trade in antiquities and art. FinCEN encourages financial institutions to continue filing SARs regarding these topics.
As a reminder, the complete contents of the Customer Identification Program Policy Template are included as Topic 7 within the Bank Secrecy Act Policy Template – Comprehensive Version.
Marketing Plan and Program Policy Template
The update to these products is in response to the FCC’s publication of a final rule in the Federal Register entitled “Limits on Exempted Calls Under the Telephone Consumer Protection Act of 1991” dated 02/25/21 that takes steps to implement the Pallone-Thune Telephone Robocall Abuse Criminal Enforcement and Deterrence Act (TRACED Act) which:
Codifies the Telephone Consumer Protection Act (TCPA) exemptions for calls to wireless numbers into the rules to make those exemptions clearer and more understandable for both callers and consumers; and
Amends the TCPA exemptions for artificial or prerecorded voice calls made to residential telephone lines so each satisfies the TRACED Act’s requirements to identify who can call, who can be called, and any call limits.
The final rule is effective March 29, 2021 except for the amendments to § 64.1200(a)(3)(ii) through (v), (b)(2) and (b)(3), and (d), which are delayed indefinitely. The FCC will publish a document in the Federal Register announcing the effective date of these amendments.
As a reminder, the complete contents of the Do-Not-Call Policy Template are included within the Marketing Plan and Program Policy Template as Topic 5.
The update to this product is in response to a revised version of the FDIC’s Consumer Compliance Examination Manual dated 03/02/21 that updated the Fair Lending Laws and Regulations and Scope and Conclusions Memorandum (IV-1.1 and IV-3.1) sections to include more information about the FDIC’s risk scoping process and instructions on how to complete the Fair Lending Scope and Conclusions memorandum. In addition, the product was updated to reflect references to other current regulatory guidance.
Keeping You Informed
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