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Product Update Blog

Product Updates May 2019

Product Updates for May 2019

The Product Updates for May 2019 from feature the following new and revised policy template products:

Bank Service Company Act Policy TemplateNEW!
Business Continuity Management Policy Template
Vendor Management Program Policy Template

These new and updated products are in response to the FDIC’s FIL-19-2019 entitled “Technology Service Provider Contracts” dated 04/02/19 that describes examiner observations about gaps in financial institutions’ contracts with technology service providers that may require financial institutions to take additional steps to manage their own business continuity and incident response.

The complete contents of the Bank Service Company Act Policy Template are included within the Vendor Management Program Policy Template as Topic 17.

Current Expected Credit Losses Policy Template

The update to this product is in response to the Joint Release entitled “Additional and Updated Interagency Frequently Asked Questions on the New Accounting Standard on Financial Instruments – Credit Losses” dated 04/03/19 which announced the publishing of additional frequently asked questions (FAQ) to assist financial institutions and examiners with the new accounting standard, Accounting Standards Update (ASU) 2016-13, Topic 326, “Financial Instruments–Credit Losses” (ASU 2016-13), issued by the Financial Accounting Standards Board (FASB) on June 16, 2016. The agencies published 23 FAQs on December 19, 2016, and published 14 additional questions on September 6, 2017. The agencies published nine additional questions, updating responses to four existing questions, and adding an appendix with links to relevant resources that are available to banks to assist with implementation of the current expected credit losses methodology (CECL).

Overdraft Policy Template

The update to this product is in response to the Federal Reserve’s Press Release entitled “Federal Reserve Board Announces Changes to its Payment System Risk Policy Regarding Intraday Credit to U.S. Branches and Agencies of Foreign Banking Organizations” dated 04/03/19 that announces a final rule implementing policy changes to procedures governing the provision of intraday credit to U.S. branches and agencies of foreign banking organizations (FBOs). The changes are intended to refine the methods for determining the level of intraday credit that these branches and agencies can receive from the Federal Reserve Banks.

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