Product Updates for May 2018
The Product Updates for May 2018 from BankPolicies.com feature the following revised policy template products:
The update to these products is in response to client requests who submitted their suggestions to our “Client Wish List” that we incorporate Basel III Capital Conversion Buffer requirements in addition to other key regulatory capital requirements. 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!
The update to these products is in response to the SBA’s publication in the Federal Register entitled “504 Loans and Debentures With 25 Year Maturity” dated 04/04/18 that announced that the SBA is making available a 504 Loan, and the Debenture that funds it, with a 25 year maturity in addition to the 10 and 20 year 504 Loan and Debenture that are currently available in the 504 Loan Program.
As a reminder, the complete contents of the Small Business Administration (SBA) Loan Policy Template are included within the Commercial Loan Policy Template as Topic 19.
The update to these products is in response to the FDIC’s Final Rule published in the Federal Register on 04/24/18 that rescinds certain capital regulations of the FDIC’s codified rules (superseded capital rules) that were no longer effective following the January 1, 2015 implementation of the revised capital rules. The final rule also makes conforming changes to sections in the FDIC’s codified rules that refer to the superseded capital rules.
The update to these products is in response to the FFIEC’s Press Release entitled “FFIEC Issues Joint Statement on Cyber Insurance and Its Potential Role in Risk Management Programs” dated 04/10/18 that describe matters that financial institutions should consider if they are determining whether to use cyber insurance as a component of their risk management programs.
As a courtesy we revised these products to eliminate any regulatory guidance that was in effect prior to the new rules that went into effect on 04/19/18.
In addition, the Regulation Z Policy Template includes a revision in response to the CFPB’s final rule entitled “Federal Mortgage Disclosure Requirements under the Truth in Lending Act (Regulation Z)” dated 04/26/18 that mends federal mortgage disclosure requirements under the Real Estate Settlement Procedures Act (RESPA) and the Truth in Lending Act (TILA) that are implemented in Regulation Z. The amendments relate to when a creditor may compare charges paid by or imposed on the consumer to amounts disclosed on a Closing Disclosure, instead of a Loan Estimate, to determine if an estimated closing cost was disclosed in good faith.