Product Updates March 2025
The Product Updates for March 2025 from BankPolicies.com feature the following revised policy template products:
Bank Secrecy Act Policy Template – Comprehensive Version
Customer Identification Program Policy Template
The update to these products is in response to FinCEN Notice FIN-2025-CTA1 entitled “FinCEN Extends Beneficial Ownership Information Reporting Deadline by 30 Days; Announces Intention to Revise Reporting Rule” dated 02/18/25 that beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect. However, because the Department of the Treasury (Treasury) recognizes that reporting companies may need additional time to comply with their BOI reporting obligations, FinCEN is generally extending the deadline 30 calendar days from February 19, 2025, for most companies.
Notably, in keeping with Treasury’s commitment to reducing regulatory burden on businesses, during this 30-day period FinCEN will assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks. FinCEN also intends to initiate a process this year to revise the BOI reporting rule to reduce burden for lower-risk entities, including many U.S. small businesses.
Cryptocurrency Policy Template
The update to this product is in response to OCC Interpretive Letter 1183 entitled “OCC Letter Addressing Certain Crypto-Asset Activities” dated 03/07/25 that rescinds Interpretive Letter 1179 (November 18, 2021). This letter reaffirms that the crypto-asset custody, distributed ledger, and stablecoin activities (hereafter, “crypto-asset activities”) discussed in prior letters are permissible. Specifically, the OCC issued three interpretive letters in 2020 and early 2021 addressing whether it is permissible for national banks and federal savings associations (collectively, “banks”) to engage in crypto-asset activities.
In addition, the OCC withdrew from two interagency statements as they apply to national banks and federal savings associations — the “Joint Statement on Crypto-Asset Risks to Banking Organizations” (January 3, 2023), and the “Joint Statement on Liquidity Risks to Banking Organizations Resulting from Crypto-Asset Market Vulnerabilities” (February 23, 2023). NOTE: For those clients that are not regulated by the OCC, the template still contains guidance mentioned in these joint statements until they are superseded and/or rescinded by the other federal regulatory agencies.
FDIC Advertising Policy Template
Marketing Plan and Program Policy Template
The update to these products is in response to the FDIC’s FIL-5-2025 entitled “Compliance Date Extension: Sections 328.4 and 328.5 Amendments to FDIC Official Signs and Advertising Requirements, False Advertising, Misrepresentation of Insured Status, and Misuse of the FDIC’s Name or Logo” dated 03/03/25 that postpones the compliance date from May 1, 2025 to March 1, 2026 for the requirements under 12 CFR 328.5 related to the display of the FDIC official digital sign on an insured depository institution’s (IDI’s) digital channels, as well as analogous requirements related to IDI’s automated teller machines (ATMs) and like devices under 12 CFR 328.4. This delay does not apply to the other amendments made by the final rule to subpart A, such that compliance for those requirements remains unchanged and is required by May 1, 2025.
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