Product Updates for May 2023
The Product Updates for May 2023 from BankPolicies.com feature the following new job description and revised policy template products:
Chief Risk Management Officer Job Description Template – NEW!
Cybersecurity Risk Manager Job Description Template – NEW!
These new products were developed in response to client requests who submitted their suggestions to our “Client Wish List.” 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 following regulatory releases:
- FDIC FIL-19-2023 entitled “Supervisory Guidance on Charging Overdraft Fees for Authorize Positive, Settle Negative Transactions” dated 04/26/23 to ensure that supervised institutions are aware of the consumer compliance risks associated with assessing overdraft fees on a transaction that was authorized against a positive balance but settled against a negative balance (APSN).
- OCC Bulletin 2023-12 entitled “Overdraft Protection Programs: Risk Management Practices” dated 04/26/23 that addresses the risks associated with overdraft protection programs. Overdraft protection programs can present a variety of risks, including compliance, operational, reputation, and credit risks. Specifically, this bulletin discusses certain practices that may present heightened risk of violating prohibitions against unfair or deceptive acts or practices. In addition, the bulletin describes practices that may assist banks with managing overdraft protection program risks. When supported by appropriate risk management practices, overdraft protection programs may assist some consumers in meeting short-term liquidity and cash-flow needs. The OCC recognizes that some banks have announced changes to their overdraft protection programs that may be consistent with appropriate risk management practices.
The update to this product is in response to the Federal Reserve’s Final Rule entitled “Regulation A: Extensions of Credit by Federal Reserve Bank” dated 05/11/23 that announced final amendments to its regulations to reflect the Federal Reserve 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 amendments to part 201 (Regulation A) are effective May 11, 2023. The rate changes for primary and secondary credit were applicable on May 4, 2023.
The update to this product is in response to the Federal Reserve’s Final Rule entitled “Regulation D: Reserve Requirements of Financial Institutions” dated 05/11/23 that announced final amendments to its regulations to revise the rate of interest paid on balances (“IORB”) maintained at Federal Reserve Banks by or on behalf of eligible institutions. The final amendments specify that IORB is 5.15 percent, a 0.25 percentage point increase from its prior level. The amendment is intended to enhance the role of IORB in maintaining the federal funds rate in the target range established by the Federal Open Market Committee (“FOMC” or “Committee”).
The amendments to part 204 (Regulation D) are effective May 11, 2023. The IORB rate change was applicable on May 4, 2023.
Current Expected Credit Losses Policy Template
The update to this product is in response to the “Interagency Policy Statement on Allowances for Credit Losses (Revised April 2023)” dated 04/21/23 that announced a revised interagency policy statement on allowances for credit losses (ACLs) (revised statement). The agencies are issuing the revised statement in response to changes to U.S. generally accepted accounting principles (GAAP) as promulgated by the Financial Accounting Standards Board (FASB) in Accounting Standards Update (ASU) 2022-02, Financial Instruments – Credit Losses (Topic 326): Troubled Debt Restructurings and Vintage Disclosures issued in March 2022.
Fair Housing Act Policy Template
Marketing Plan and Program Policy Template
The update to these products is in response to the FDIC’s “Fair Housing Rule, Consumer Protection in Sales of Insurance Rule; Technical Correction” dated 04/24/23 that announced a technical correction to the FDIC’s Fair Housing Rule to reinsert a previous instruction regarding the Equal Housing Lending Poster. The rule is effective June 23, 2023.
Keeping You Informed
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