Product Update Blog

Product Updates for May 2021

The Product Updates for May 2021 from BankPolicies.com feature the following revised policy template products:

Bank Secrecy Act Policy Template – Basic Version

Bank Secrecy Act Policy Template – Comprehensive Version

Model Risk Management Program Policy Template

The update to these products is in response to the “Interagency Statement on Model Risk Management for Bank Systems Supporting Bank Secrecy Act/Anti-Money laundering Compliance” dated 04/09/21 that announced the issuance of a joint statement addressing how risk management principles described in the “Supervisory Guidance on Model Risk Management” relate to systems or models used by banks to assist in complying with the requirements of Bank Secrecy Act (BSA) laws and regulations.  The statement further notes that it does not alter existing BSA/anti-money laundering (AML) legal or regulatory requirements or establish new supervisory expectations, and that no specific model risk management framework is required.

Current Expected Credit Losses Policy Template

The update to this product is in response to the OCC Bulletin 2021-20 entitled “Allowances for Credit Losses: New Comptroller’s Handbook Booklet” dated 04/15/21 that announced a new “Allowances for Credit Losses” booklet of the Comptroller’s Handbook.  The booklet provides information and examination procedures regarding allowances for credit losses (ACL), and applies to the supervision of banks that have adopted the current expected credit losses (CECL) methodology under Accounting Standards Codification (ASC) Topic 326.  The “Allowance for Loan and Lease Losses” booklet of the Comptroller’s Handbook continues to apply to the OCC’s supervision of banks that have not adopted CECL.

Fair Debt Collection Practices Act Policy Template

The update to this product is in response to the CFPB’s Interim Final Rule entitled “CFPB Rule Clarifies Tenants Can Hold Debt Collectors Accountable for Illegal Evictions” dated 04/19/21 that announced an interim final rule in support of the Centers for Disease Control and Prevention (CDC)’s eviction moratorium.  The CFPB’s rule requires debt collectors to provide written notice to tenants of their rights under the eviction moratorium and prohibits debt collectors from misrepresenting tenants’ eligibility for protection from eviction under the moratorium.  The CDC has established the eviction moratorium to protect the public health and reduce the spread of the virus.  Debt collectors who evict tenants who may have rights under the moratorium without providing notice of the moratorium or who misrepresent tenants’ rights under the moratorium can be prosecuted by federal agencies and state attorneys general for violations of the Fair Debt Collection Practices Act (FDCPA) and are also subject to private lawsuits by tenants.  The interim final rule is effective 05/03/21.

Keeping You Informed

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