Product Updates May 2026
The Product Updates for May 2026 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 FDIC FIL-16-2026 entitled “Agencies Revise the Interagency Model Risk Management Guidance” and OCC Bulletin 2026-13 entitled “Model Risk Management; Revised Guidance” dated 04/17/26 that announced the FDIC, OCC, and the Federal Reserve System issued revised model risk management guidance and rescinded numerous existing model risk management guidance.
Capital Planning Program Policy Template
Corporate Governance Policy Template
The update to these products is in response to the Joint Press Release entitled “Agencies Finalize Changes to Enhance Community Bank Leverage Ratio” dated 04/23/26 that finalized a rule to modify the community bank leverage ratio consistent with existing statutory authority. This change provides community banks with greater flexibility to use a simpler measure of capital adequacy and reduce regulatory burden. The final rule takes into account the unique business models and risk profiles of community banks.
In general, the rule lowers the community bank leverage ratio from nine percent to eight percent, which will provide more flexibility for community banks to opt into the framework. In addition, the final rule extends the grace period from two quarters to four quarters for a community bank that temporarily falls out of compliance. The framework continues to simplify regulatory capital requirements for community banks by allowing them to adopt a relatively simple leverage ratio to measure capital adequacy, rather than calculating and reporting risk-based capital ratios.
Community banks that opt into the framework will be subject to a capital requirement that continues to promote safety and soundness. Under the framework, banks must maintain a leverage ratio that is significantly higher than the leverage ratio standard otherwise applicable to community banks.
The changes are effective July 1, 2026.
The update to this product is in response to the CFPB’s final rule that amends provisions related to disparate impact, discouragement of applicants or prospective applicants, and special purpose credit programs under Regulation B, the regulation implementing the Equal Credit Opportunity Act (ECOA or Act). The amendments facilitate compliance with ECOA by clarifying the obligations imposed by the statute. This final rule is effective July 21, 2026.
Fair Credit Reporting Act Policy Template
Fair Debt Collection Practices Act Policy Template
Faith-Based Organization Loan Policy Template
Flooring Lines of Credit Policy Template
Human Resources Code of Ethics Policy Template
Human Resources General Policy Template
Human Resources Incentive Compensation Policy Template
Human Resources Salary Administration Policy Template
Identity Theft Program Policy Template
Incident Response and Preparedness Policy Template
Information Systems Security Policy Template
Information Technology Audit Policy Template
Interest Rate Risk Policy Template
Internet Banking Policy Template
Lease Financing Policy Template
Litigation Risk Management Program Policy Template
Marketing Plan and Program Policy Template
Merchant Services Program Policy Template
Mobile Banking Policy Template
Mobile Remote Deposit Capture Program Policy Template
Model Risk Management Program Policy Template
Non-Accrual and Charged-Off Loan Policy Template
Oil and Gas Industry Loan Policy Template
The update to these products is in response to FDIC FIL-13-2026 entitled “Agencies Issue Final Rule to Prohibit Use of Reputation Risk by Regulators” and OCC Bulletin 2026-12 entitled “Prohibition on Use of Reputation Risk by Regulators: Final Rule” dated 04/07/26 that announced a final rule to codify the removal of reputation risk from their supervisory programs. In general, the final rule:
- Prohibits the agencies from criticizing, formally or informally, or taking adverse action against a supervised institution or any employee of an institution on the basis of reputation risk.
- Prohibits the agencies from requiring, instructing, or encouraging an institution to close customer accounts or take other actions on the basis of a person’s or entity’s political, social, cultural, or religious views or beliefs, constitutionally protected speech, or solely on the basis of politically disfavored but lawful business activities perceived to present reputation risk.
- Does not impose requirements or obligations on supervised institutions.
- Defines “reputation risk” as any risk, regardless of how that risk is labeled, that an action or activity of an institution could negatively impact public perception of the institution for reasons not clearly and directly related to the financial or operational condition of the institution.
The final rule takes effect 60 days after the date of publication in the Federal Register.
NOTE: We will continue to issue updates to several of our other products affected by this regulatory guidance over the next few releases and we appreciate your patience.
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