Revised Policy Templates for May 2016
Consumer Loan Policy Template
Non-Accrual and Charged-Off Loan Policy Template
Other Real Estate Owned Policy Template
Risk Management of Foreclosure Policy Template
Risk Management of Subprime Mortgage Lending Policy Template
Servicemembers Civil Relief Act Policy Template
Troubled Debt Restructuring and Loan Workout Program Policy Template
These products were revised in response to the “Foreclosure Relief and Extension of Servicemembers Act of 2015” that was signed into law on 03/31/16. The act amends the dates in Section 710(d) of the “Honoring America’s Veterans and Caring for Camp Lejeune Families Act of 2012 (Public Law 112-154) to extend the sunset in that act of the temporary substitution of “one year” for “90 days” in sections 303(b) and (c) of the Servicemembers Civil Relief Act (50 U.S.C. 3953). The new sunset date is December 31, 2017.
These products were revised in response to the FFIEC’s Press Release entitled “Financial Regulators Release New Appendix for Retail Payment Systems Booklet – Appendix E: Mobile Financial Services” dated April 29, 2016 that announced a revised Retail Payment Systems booklet, which is part of the FFIEC Information Technology Examination Handbook (IT Handbook). The update consists of the addition of a new appendix, Appendix E: Mobile Financial Services. The new Appendix E contains guidance pertaining to mobile financial services risks that supplements existing booklet guidance on other retail payment topics, such as electronic payments related to credit cards and debit cards, remote deposit capture and changes in technology of retail payment systems.
As a reminder, the complete contents of the Mobile Banking Policy Template are included within the Internet Banking Policy Template as Topic 12, whereas the complete contents of the Mobile Remote Deposit Capture Program Policy Template are included within the Remote Deposit Capture Program Policy Template as Topic 12.