New and Revised Policy Templates for May 2017
These new and revised products were developed in response to client requests that we develop a policy that addresses certain provisions of the Americans with Disabilities Act (ADA) that are applicable to financial institutions. The update to the Human Resources General Policy Template expands upon applicability with regards to employment, whereas the revision to the Internet Banking Policy Template incorporates ADA website standards.
The update to this product is in response to the OCC’s Bulletin 2017-15 issued on 04/12/17 that announced a new “Retail Lending” booklet. This new booklet discusses the risks associated with retail lending and provides a framework for conducting and evaluating retail credit risk management activities.
The update to this product is in response to the Federal Reserve’s Final Rule issued on 04/18/17 that adopted final amendments to its Regulation A to reflect the Board’s approval of an increase in the rate for primary credit at each Federal Reserve Bank. The secondary credit rate at each Reserve Bank automatically increased by formula as a result of the Board’s primary credit rate action.
The update to this product is in response to the Federal Reserve’s Final Rule issued on 04/18/17 that revises the rate of interest paid on balances maintained to satisfy reserve balance requirements (IORR) and the rate of interest paid on excess balances (IOER) maintained at Federal Reserve Banks by or on behalf of eligible institutions. The final amendments specify that IORR is 1.00 percent and IOER is 1.00 percent, a 0.25 percentage point increase from their prior levels.
The update to these products is in response to the CFPB’s notice entitled “CFPB Finalizes Effective Date Extension for Prepaid Account Rule” issued on 04/20/17 that announces a final rule delaying the general effective date of their rule governing prepaid accounts by six months. The rule will now take effect on April 1, 2018.