Product Update Blog

Product Updates November 2025

The Product Updates for November 2025 from BankPolicies.com feature the following revised policy template products:

Automated Clearing House Policy Template

Bank Secrecy Act Policy Template – Comprehensive Version

Office of Foreign Assets Control Policy Template

The update to these products is in response to the following Nacha releases:

Definition and IAT Entries – Effective September 18, 2026

Registration of IAT Contacts in the ACH Contact Registry – Effective January 1, 2027

International ACH Transactions(IAT) – Effective March 19, 2027

New Return Reason Code for Sanctions Compliance Obligations – Effective March 17, 2028

Current Expected Credit Losses Policy Template

The update to this product is in response to FASB Accounting Standards Update No. 2025-05 entitled “Financial Instruments – Credit Losses (Topic 326) Measurement of Credit Losses for Accounts Receivable and Contract Assets” dated July 2025 that addresses challenges encountered when applying the guidance in Topic 326, Financial Instruments—Credit Losses, to current accounts receivable and current contract assets arising from transactions accounted for under Topic 606, Revenue from Contracts with Customers.  The amendments in this update introduce a practical expedient for all entities and an accounting policy election for entities other than public business entities related to applying Subtopic 326-20 to current accounts receivable and current contract assets arising from transactions accounted for under Topic 606.

Regulation A Policy Template

The update to this product is in response to the Federal Reserve’s Final Rule entitled “Regulation A: Extensions of Credit by Federal Reserve Banks” dated 11/14/25 that announced final amendments to its regulations to reflect the Federal Reserve Board’s approval of a decrease in the rate for primary credit at each Federal Reserve Bank.  The secondary credit rate at each Reserve Bank automatically decreased by formula as a result of the Board’s primary credit rate action.

The amendments to part 201 (Regulation A) are effective 11/14/25.  The rate changes for primary and secondary credit were applicable on 10/30/25.

Regulation D Policy Template

The update to this product is in response to the Federal Reserve’s Final Rule entitled “Regulation D: Reserve Requirements of Financial Institutions” dated 11/14/25 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 3.90 percent, a 0.25 percentage point decrease 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 11/14/25.  The IORB rate change was applicable on 10/30/25.

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