Product Updates May 2025
The Product Updates for May 2025 from BankPolicies.com feature the following revised policy template products:
Accounts Payable and Employee Expense Policy Template
The update to this product is in response to the Department of the Treasury’s final rule entitled “Eliminating Unnecessary Regulations” dated 04/15/25 that streamlines titles 12 and 31 of the Code of Federal Regulations (CFR) by removing regulations that are no longer necessary or no longer have any current or future applicability. This rule is effective 06/16/25 without further action, unless significant adverse comment is received by 05/15/25. If the Treasury receives significant adverse comments, it will publish a timely withdrawal in the Federal Register informing the public that this rule or a portion thereof will not take effect.
Asset, Liability, and Liquidity Management Policy Template
The update to this product is in response to:
- OCC Interpretive Letter 1183 entitled “OCC Letter Addressing Certain Crypto-Asset Activities” dated 03/07/25 that rescinds Interpretive Letter 1179 (November 18, 2021) and the withdrawal from two interagency statements as they apply to national banks and federal savings associations — the “Joint Statement on Crypto-Asset Risks to Banking Organizations” (January 3, 2023), and the “Joint Statement on Liquidity Risks to Banking Organizations Resulting from Crypto-Asset Market Vulnerabilities” (February 23, 2023).
- FDIC FIL-7-2025 entitled “FDIC Clarifies Process for Banks to Engage in Crypto-Related Activities” dated 03/28/25 that rescinds FIL-16-2022 and provides new guidance for FDIC-supervised institutions engaging or seeking to engage in crypto-related activities. In addition, the FDIC will work with the other banking agencies to replace interagency documents issued in January 2023 and February 2023 related to crypto-assets with further guidance or regulations.
BSA Suspicious Activity Report Notices Template
The update to this product is in response to FinCEN Alert FIN-2025-Alert002 entitled “FinCEN Alert on Oil Smuggling Schemes on the U.S. Southwest Border Associated with Mexico-Based Cartels” dated 05/01/25 urging financial institutions to be vigilant in detecting, identifying, and reporting suspicious activity connected to the smuggling of stolen crude oil from Mexico across the U.S. southwest border into the United States by the Jalisco New Generation Cartel (CJNG), Sinaloa Cartel, Gulf Cartel, and other Mexico-based transnational criminal organizations (TCOs) — frequently known as the “Cartels.” In recent years, fuel theft in Mexico, including crude oil smuggling, has become the most significant non-drug illicit revenue source for the Cartels and enables them to sustain their global criminal enterprises and drug trafficking operations into the United States. This alert is being issued in coordination with an OFAC sanctions action.
As a reminder, the BSA Suspicious Activity Report Notices Template is included in the purchase price of the Bank Secrecy Act Policy Template – Comprehensive Version.
Commercial Loan Policy Template
Small Business Administration Loan Policy Template
The update to these products is in response to the following SBA’s News Releases:
- 2542 entitled “SBA Highlights Range of New Measures to Stop Fraud” dated 04/10/25 that highlights several new verification measures within its loan application process to strengthen protections against fraud and ensure its programs only benefit eligible American small business owners.
- 2545 entitled “SBA Eliminates Disastrous Biden-Era Underwriting Standards” dated 04/22/25 that announced the elimination of a package of Biden-era policies which dramatically reduced underwriting standards within the 7(a) loan program, sacrificing its financial integrity and driving up taxpayer liability. Under the leadership of Administrator Kelly Loeffler, the SBA is restoring robust rules to end the era of reckless lending, thereby preserving access to capital for America’s small business owners and safeguarding taxpayer dollars. SOP 50 10 is effective 06/01/25.
Compliance Management Policy Template
The update to this product is in response to FDIC FIL-9-2025 entitled “Supervisory Correspondence: Electronic Communication Adopted as the Preferred Method” dated 04/15/25 that announced the FDIC is making permanent the establishment of electronic communications as the preferred method for supervisory correspondence. This makes permanent the alternative secure mail procedures that were initially implemented on a temporary basis in March 2020.
Cryptocurrency Policy Template
The update to this product is in response to OCC Interpretive Letter #1184 entitled “Clarification of Bank Authority Regarding Crypto-Asset Custody Services” dated 05/07/25 that clarified permissible bank activities related to crypto-asset custody and execution services.
The OCC published Interpretive Letter 1184 to confirm that national banks and federal savings associations may buy and sell assets held in custody at the customer’s direction and are permitted to outsource to third parties bank-permissible crypto-asset activities, including custody and execution services, subject to appropriate third-party risk management practices. This authority was also addressed in OCC Interpretive Letters 1170 and 1183.
As with any activity, a bank must conduct crypto-asset custody activities, including via a sub-custodian, in a safe and sound manner and in compliance with applicable law.
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