Product Updates November 2024
The Product Updates for November 2024 from BankPolicies.com feature the following new and revised policy and form template products:
Personal Financial Data Rights Policy Template – NEW!
This new product was developed in response to the CFPB’s final rule entitled “Required Rule Making on Personal Financial Data Rights” dated 10/22/24 that carries out the personal financial data rights established by the Consumer Financial Protection Act of 2010 (CFPA). The final rule requires banks, credit unions, and other financial service providers to make consumers’ data available upon request to consumers and authorized third-parties in a secure and reliable manner; defines obligations for third-parties accessing consumers’ data, including important privacy protections; and promotes fair, open, and inclusive industry standards. This final rule is effective 60 days after the date of publication in the federal register. Data providers must comply with the requirements in subparts B and C beginning April 1, 2026; April 1, 2027; April 1, 2028; April 1, 2029; or April 1, 2030, depending on the criteria set forth in § 1033.121(c).
Automated Clearing House Policy Template
The update to this product is in response to Nacha ACH Operations Bulletin #3-2024 entitled “Open Banking and ACH Payments: The Impact of the CFPB’s Personal Financial Data Rights Final Rule” dated 10/31/24 that provides an overview of the Personal Financial Data Rights Final Rule and an initial assessment of its applicability and impact on ACH Network participants and ACH payments.
Bank Secrecy Act Policy Template – Comprehensive Version
Customer Identification Program Policy Template
The update to these products is in response to FinCEN’s final rule entitled “Update to the Public Utility Exemption Under the Beneficial Ownership Information Reporting Rule” dated 10/18/24 that clarifies an exemption under the beneficial ownership information reporting rule that FinCEN published on September 30, 2022. This rule modifies the language exempting certain public utilities from the definition of “reporting company” in the beneficial ownership information reporting rule to more clearly implement the language of the exemption found in the Corporate Transparency Act.
BSA Suspicious Activity Report Notices Template
The update to this product is in response to FinCEN Alert FIN-2024-Alert003 entitled “FinCEN Alert to Financial Institutions to Counter Financing of Hizballah and its Terrorist Activities” dated 10/23/24 that supplements the information related to Hizballah’s financing outlined in FinCEN’s 2024 Advisory on Iran-Backed Terrorist Organizations.
As a reminder, the BSA Suspicious Activity Report Notices Template is included in the purchase price of the Bank Secrecy Act Policy Template – Comprehensive Version.
FDIC Advertising Policy Template
Marketing Plan and Program Policy Template
The update to these products is in response to the FDIC’s FIL-75-2024 entitled “Compliance Date Extension: Part 328, Subpart A Amendments to FDIC Official Signs and Advertising Requirements, False Advertising, Misrepresentation of Insured Status, and Misuse of the FDIC’s Name or Logo Rule” dated 10/17/24 that extends the compliance date for amendments to part 328 subpart A of its regulations to modernize the rules governing use of the official FDIC sign and insured depository institutions’ (IDIs’) advertising statements from January 1, 2025, to May 1, 2025. This extension will provide additional opportunity for IDIs to establish processes and systems, and make technological updates, necessary to implement the new regulatory requirements under subpart A. The compliance date for amendments to part 328, subpart B, relating to misrepresentations of deposit insurance, remains January 1, 2025.
Keeping You Informed
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