Product Updates October 2017 is providing you with these product updates as a courtesy to all of our clients.  If you have any questions, please contact us.

New and Revised Policy and Form Templates

Arbitration Agreements Policy TemplateNEW!

This new product was developed in response to the CFPB’s Press Release dated 07/10/17 that announced a new rule to ban companies from using mandatory arbitration clauses to deny groups of people their day in court.  The CFPB’s new rule will deter wrongdoing by restoring consumers’ right to join together to pursue justice and relief through group lawsuits.  The rule has an effective date of 09/18/17, and compliance required in contracts entered into on or after 03/19/18.

Asset, Liability and Liquidity Management Policy Template
Liquidity Contingency Funding Plan Policy Template

The update to these products is in response to FDIC’s Supervisory Insights – Summer 2017 publication dated 08/30/17 that illustrates the importance of liquidity risk management as many institutions continue to reduce holdings of liquid assets.  The article reiterates principles outlined in existing supervisory guidance and is intended as a resource for bankers who wish to heighten awareness of prudent liquidity and funds management.

As a reminder, the complete contents of the Contingency Funding Plan Policy Template are included within the Asset, Liability and Liquidity Management Policy Template as Topic 7.

BSA Certification for Beneficial Owners Form Template

The update to this product (included with the purchase price of the Bank Secrecy Act Policy Template – Comprehensive Version or Customer Identification Program Policy Template) is in response to FinCEN’s Technical Corrections to Customer Due Diligence Final Rule dated 09/29/17 that makes minor, non-substantive, and technical corrections to the final rule regarding Customer Due Diligence, which was published in the Federal Register on Wednesday, May 11, 2016.

Flood Disaster Protection Act Policy Template

The update to this product (formerly named the Flood Hazard Insurance Policy Template) is in response to the OCC’s Bulletin 2017-35 dated 09/07/17 that announced a revised “Flood Disaster Protection Act” booklet of the Comptroller’s Handbook.  The revised booklet provides information on changes to the flood insurance requirements resulting from recent amendments to the Flood Disaster Protection Act (FDPA) and the flood insurance regulations and makes other clarifying changes.

Regulation B Policy Template

The update to this product is in response to the CFPB’s Final Rule dated 09/20/17 that modified Equal Credit Opportunity Act (ECOA) regulations to provide additional flexibility for mortgage lenders in the collection of consumer ethnicity and race information.  The rule is effective on January 1, 2018, except that the amendment to Appendix B removing the existing “Uniform Residential Loan Application” form in amendatory instruction 6 is effective January 1, 2022.

Regulation X Policy Template

The update to this product is in response to the CFPB’s Interim Final Rule entitled “Amendments to the 2016 Amendments to the 2013 Mortgage Servicing Rules Under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z)” dated 10/04/17 that announced an interim final rule amending a provision of the Regulation X mortgage servicing rules that it issued in 2016 relating to the timing for mortgage servicers to provide modified written early intervention notices to borrowers who have invoked their cease communication rights under the Fair Debt Collection Practices Act.  The Interim Final Rules is effective on 10/19/17.