Product Update Blog

Product Updates for November 2020

The Product Updates for November 2020 from feature the following revised policy template products:

Bank Secrecy Act Policy Template – Comprehensive Version

The update to this products is in response to FinCEN’s:

Advisory FIN-2020-A007 entitled “Advisory on Unemployment Insurance Fraud During the Coronavirus Disease 2019 (COVID-19) Pandemic” dated 10/13/20 that alerts financial institutions to unemployment insurance (UI) fraud observed during the COVID-19 pandemic.  Many illicit actors are engaged in fraudulent schemes that exploit vulnerabilities created by the pandemic.  This advisory contains descriptions of COVID-19-related UI fraud, associated financial red flag indicators, and information on reporting suspicious activity.

Advisory FIN-2020-A008 entitled “Supplemental Advisory on Identifying and Reporting Human Trafficking and Related Activity” dated 10/15/20 to help save lives, and to protect the most vulnerable in our society from predators and cowards who prey on the innocent and defenseless for money and greed.  This advisory supplements the 2014 FinCEN Guidance on Recognizing Activity that May be Associated with Human Smuggling and Human Trafficking – Financial Red Flags (“2014 Advisory”).

Concentrations of Credit Policy Template

The update to this product is in response to OCC Bulletin 2020-90 entitled “Concentrations of Credit – Revised Comptroller’s Handbook and Rescissions” dated 10/26/20 that announced a revised “Concentrations of Credit” booklet of the Comptroller’s Handbook.  The revised booklet replaces version 1.0 of the “Concentrations of Credit” booklet and rescinds OCC Bulletin 2011-48, “Credit Policy: Concentrations of Credit: Revised Booklet,” which transmitted version 1.0 of the booklet in December 2011.

Fair Debt Collection Practices Act Policy Template

The update to this product is in response to the CFPB’s Press Release entitled “Consumer Financial Protection Bureau Issues Final Rule to Implement the Fair Debt Collection Practices Act” dated 10/30/20 that issued a final rule to restate and clarify prohibitions on harassment and abuse, false or misleading representations, and unfair practices by debt collectors when collecting consumer debt.  The rule focuses on debt collection communications and gives consumers more control over how often and through what means debt collectors can communicate with them regarding their debts.  The rule also clarifies how the protections of the Fair Debt Collection Practices Act (FDCPA), which was passed in 1977, apply to newer communication technologies, such as e-mail and text messages.

The final rule does contain provisions on disputes, and record retention, among other topics.  It does not include a proposed safe harbor for debt collectors against claims that an attorney falsely represented the attorney’s involvement in the preparation of a litigation submission.  The CFPB intends to issue a second debt collection final rule focused on consumer disclosures and collection of time-barred debts in December 2020.

The rule, which is a complete revision and restatement of the CFPB’s Regulation F (12 CFR Part 1006), is effective one year after it is published in the Federal Register (11/30/21).

Regulation Z Policy Template

The update to this product is in response to the CFPB’s Final Rule entitled “Qualified Mortgage Definition under the Truth in Lending Act (Regulation Z): Extension of Sunset Date” dated 10/20/20 that amends Regulation Z to replace the January 10, 2021 sunset date of the Temporary GSE QM loan definition with a provision stating that the Temporary GSE QM loan definition will be available only for covered transactions for which the creditor receives the consumer’s application before the mandatory compliance date of final amendments to the General QM loan definition in Regulation Z.  This final rule does not amend the provision stating that the Temporary GSE QM loan definition expires with respect to a GSE when that GSE exits conservatorship.

Keeping You Informed

We provide this Product Update Blog as a courtesy to all clients regarding new and revised products released by  We feel that it is important to keep our clients well informed of changes to the financial institution industry, including keeping on top of federal regulatory changes, and industry recommended best practices.  In this regard, we encourage you to subscribe to our newsletter in which these types of announcements are made including any special offers that can save you time and money.  Just contact us to be added to our distribution list.

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