Product Updates for November 2022
The Product Updates for November 2022 from BankPolicies.com feature the following revised policy template products:
Fair Credit Reporting Act Policy Template
Identity Theft Program Policy Template
The update to these products is in response to the Federal Reserve’s FedPayments Improvement Group inclusion of additional modules within its “Synthetic Identity Fraud Mitigation Toolkit.” In general, the Synthetic Identity Fraud Mitigation Toolkit was developed by the Federal Reserve to help educate the industry about synthetic identity fraud and outline potential ways to help detect and mitigate this fraud type. Insights for this toolkit were provided through interviews with industry experts, publicly available research, and team member expertise.
The update to this product is in response to the CFPB’s release entitled “CFPB Issues Guidance to Help Banks Avoid Charging Illegal Junk Fees On Deposit Accounts” dated 10/26/22 that announced issued guidance about two junk fee practices that are likely unfair and unlawful under existing law. The first, surprise overdraft fees, includes overdraft fees charged when consumers had enough money in their account to cover a debit charge at the time the bank authorizes it. The second is the practice of indiscriminately charging depositor fees to every person who deposits a check that bounces. The penalty is an unexpected shock to depositors who thought they were increasing their funds.
The update to this product is in response to the Federal Reserve’s final rule entitled “Regulation A: Extensions of Credit by Federal Reserve Bank” dated 10/07/22 that announced final amendments to its regulations to reflect the Federal Reserve Board’s approval of an increase in the rate for primary credit at each Federal Reserve Bank. The secondary credit rate at each Reserve Bank automatically increased by formula as a result of the Board’s primary credit rate action.
The amendments to part 201 (Regulation A) are effective October 7, 2022. The rate changes for primary and secondary credit were applicable on September 22, 2022.
The update to this product is in response to the Federal Reserve’s final rule entitled “Regulation D: Reserve Requirements of Financial Institutions” dated 10/07/22 that announced final amendments to its regulations to revise the rate of interest paid on balances (“IORB”) maintained at Federal Reserve Banks by or on behalf of eligible institutions. The final amendments specify that IORB is 3.15 percent, a 0.75 percentage point increase from its prior level. The amendment is intended to enhance the role of IORB in maintaining the federal funds rate in the target range established by the Federal Open Market Committee (“FOMC” or “Committee”).
The amendments to part 204 (Regulation D) are effective October 7, 2022. The IORB rate change was applicable on September 22, 2022.
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