Product Updates for November 2018
The Product Updates for November 2018 from BankPolicies.com feature the following revised policy template products:
The update to these products is in response to OCC Bulletin 2018-38 dated 08/31/18 that announced the availability of a revised “Agricultural Lending” booklet and “Oil and Gas Exploration and Production Lending” booklet of the Comptroller’s Handbook which replaces the booklets of the same title issued in January 2017.
As a reminder, the complete contents of the Agricultural Loan Policy Template and the Oil and Gas Industry Loan Policy Template are included within the Commercial Loan Policy Template as Topics 24 and 27 respectively.
The update to the Bank Secrecy Act Policy Template – Comprehensive Version and Bank Secrecy Act Policy Template – Basic Version is in response to the Joint Statement entitled “Federal Agencies Issue a Joint Statement on Banks and Credit Unions Sharing Resources to Improve Efficiency and Effectiveness of Bank Secrecy Act Compliance” dated 10/03/18 to address instances in which certain banks and credit unions may decide to enter into collaborative arrangements to share resources to manage their Bank Secrecy Act (BSA) and anti-money laundering (AML) obligations more efficiently and effectively.
In addition, the update to the Bank Secrecy Act Policy Template – Comprehensive Version and Customer Identification Program Policy Template is in response to FinCEN’s Press Release entitled “Federal Banking Agencies and FinCEN Announce Exemption from Customer Identification Program Requirements for Premium Finance Loans” dated 09/28/18 that announced an order granting an exemption from customer identification program requirements implementing section 326 of the USA PATRIOT Act, 31 U.S.C. § 5318(l), for loans extended by banks (and their subsidiaries) subject to the jurisdiction of the Federal Banking Agencies to commercial customers to facilitate purchases of property and casualty insurance policies.
The update to this product is in response to the Federal Reserve’s Press Release dated 10/25/18 that announced the annual indexing of two amounts used in determining reserve requirements of depository institutions. These amounts are the reserve requirement exemption amount and the low reserve tranche.