Product Updates March 2022

Product Update Blog

Product Updates for March 2022

The Product Updates for March 2022 from feature the following revised policy template products:

Bank Secrecy Act Policy Template – Comprehensive Version

The update to this product is in response to FinCEN Alert FIN-2022-Alert001 entitled “FinCEN Advises Increased Vigilance for potential Russian Sanctions Evasion Attempts” dated 03/07/22 that alerts all financial institutions to be vigilant against efforts to evade the expansive sanctions and other U.S.-imposed restrictions implemented in connection with the Russian Federation’s further invasion of Ukraine.  The United States is committed to supporting Ukraine, and, along with key U.S. partners and allies around the globe, has imposed unprecedented economic pressure measures on Russia and Belarus.  This alert provides select red flags to assist in identifying potential sanctions evasion activity and reminds financial institutions of their Bank Secrecy Act (BSA) reporting obligations, including with respect to convertible virtual currency (CVC).

Consumer Loan Policy Template

Student Loan Program Policy Template

The update to these products is in response to the CFPB’s Bulletin 2022-03 entitled “Servicer Responsibilities in Public Service Loan Forgiveness Communications ” dated 02/18/22 regarding the servicing of federal student loans, including Federal Family Education Loan Program and Perkins loans, for borrowers who may be eligible for Public Service Loan Forgiveness (PSLF).  The Limited PSLF Waiver announced by the Department of Education on October 6, 2021 (PSLF Waiver) significantly changes the program’s eligibility criteria for a limited period.  In communicating with borrowers about the PSLF program, servicers should consider taking certain actions to ensure compliance with the Dodd-Frank Wall Street Reform and Consumer Protection Act’s (Dodd-Frank Act’s) prohibition on unfair, deceptive, or abusive acts or practices (collectively, UDAAPs).  In its oversight, the CFPB will be paying particular attention to whether student loan servicers provide complete and accurate information to consumers about the benefits they can receive under the PSLF Waiver and eligibility for PSLF generally.

Fair Credit Reporting Act Policy Template

Fraud Policy Template

Identity Theft Program Policy Template

The update to these products is in response to the Federal Reserve’s FedPayments Improvement Group release entitled “Unmasking a Synthetic Identity Fraud Mitigation Toolkit” dated 02/09/22 that announced a new Synthetic Identity Fraud Mitigation Toolkit.  The toolkit will be expanded from time to time, and provides useful insights and resources for identifying and mitigating synthetic fraud to:

  • Increase education and awareness about synthetic identity fraud;
  • Enable the payments industry to better identify and fight synthetic identity fraud; and
  • Foster payments industry collaboration on synthetic identity fraud mitigation.

Unfair, Deceptive, or Abusive Acts or Practices Policy Template

The update to this product is in response to the CFPB’s Bulletin 2022-04 entitled “Mitigating Harm from Repossession of Automobiles” dated 02/28/22 regarding repossession of vehicles, and the potential for violations of sections 1031 and 1036 of the Dodd-Frank Wall Street Reform and Consumer Protection Act’s (Dodd-Frank Act) prohibition on engaging in unfair, deceptive, or abusive acts or practices when repossessing vehicles.  The CFPB intends to hold loan holders and servicers accountable for UDAAPs related to the repossession of consumers’ vehicles.

Keeping You Informed

We provide this Product Update Blog as a courtesy to all clients regarding new and revised products released by  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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