Product Updates for November 2021
The Product Updates for November 2021 from BankPolicies.com feature the following new policy, new job descriptions and revised policy template products:
These new and revised products are in response to OCC Bulletin 2021-49 entitled “Payment Systems: Revised Comptroller’s Handbook Booklet and Rescissions” dated 10/21/21 that announced a revised “Payment Systems” booklet of the Comptroller’s Handbook that replaces the:
- “Payment Systems and Funds Transfer Activities” booklet of the Comptroller’s Handbook, dated March 1990.
- Office of Thrift Supervision Examination Handbook section 580, “Payments Systems Risk,” dated January 1994.
- Banking Circular 235, “International Payments Systems Risks,” dated May 10, 1989.
- OCC Bulletin 1996-48, “Stored Value Card Systems: Information for Bankers and Examiners,” dated September 3, 1996.
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 FDIC’s final rule entitled “Real Estate Lending Standards” dated 10/22/21 that incorporates consideration of the community bank leverage ratio (CBLR) rule, which does not require electing institutions to calculate tier 2 capital or total capital, into the Real Estate Lending Standards. The final rule allows a consistent approach for calculating the ratio of loans in excess of the supervisory loan-to-value limits (LTV Limits) at all FDIC-supervised institutions, using a methodology that approximates the historical methodology the FDIC has followed for calculating this measurement without requiring institutions to calculate tier 2 capital. The final rule also avoids any regulatory burden that could arise if an FDIC-supervised institution subsequently decides to switch between different capital frameworks.
In addition, the Consumer Loan Policy Template was updated in response to the OCC Bulletin 2021-52 entitled “Retail Lending: Revised Comptroller’s Handbook Booklet and Rescissions” dated 10/28/21 that issued version 2.0 of the “Retail Lending” booklet of the Comptroller’s Handbook. This booklet discusses risks associated with retail lending and provides a framework for examiners’ evaluations of risk management activities, and rescinds the following documents:
- OCC Bulletin 2017-15, “Retail Lending: New Comptroller’s Handbook Booklet”
- “Retail Lending” booklet of the Comptroller’s Handbook, version 1.1
The update to this product is in response to the EEOC’s guidance entitled “Sexual Orientation and Gender Identity (SOGI) Discrimination” that describes federal protections from discrimination and retaliation based on applicants’ or employees’ sexual orientation and transgender status.
The update to this product is in response to the CFPB’s Final Rule entitled “Truth in Lending (Regulation Z) Annual Threshold Adjustments (Credit Card, HOEPA, and Qualified Mortgages)” dated 10/25/21 that amends the official interpretations for Regulation Z, which implements the Truth in Lending Act (TILA). The CFPB is required to calculate annually the dollar amounts for several provisions in Regulation Z, and this final rule reviews the dollar amounts for provisions implementing TILA and amendments to TILA, including under the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act), the Home Ownership and Equity Protection Act of 1994 (HOEPA), and the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). This final rule is effective January 1, 2022.
Keeping You Informed
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