Product Updates for October 2018
The Product Updates for October 2018 from BankPolicies.com feature the following revised policy template products:
The update to these products is in response to FinCEN Ruling FIN-2018-R003 entitled “Exceptive Relief from Beneficial Ownership Requirements for Legal Entity Customers of Rollovers, Renewals, Modifications, and Extensions of Certain Accounts” dated 09/07/18 that granted exceptive relief to covered financial institutions (banks, brokers or dealers in securities, mutual funds, futures commission merchants, and introducing brokers in commodities) from the obligations of the Beneficial Ownership Requirements for Legal Entity Customers (Beneficial Ownership Rule) and its requirement to identify and verify the identity of the beneficial owner(s) when a legal entity customer opens a new account as a result of a:
- Rollover of a certificate of deposit (CD);
- Renewal, modification, or extension of a loan (e.g., setting a later payoff date) that does not require underwriting review and approval;
- Renewal, modification, or extension of a commercial line of credit or credit card account (e.g., a later payoff date is set) that does not require underwriting review and approval; and
- Renewal of a safe deposit box rental.
The update to these products is in response to OCC Bulletin 2018-28 dated 08/31/18 that announced the availability of a revised “Deposit-Related Credit” booklet of the Comptroller’s Handbook which replaces the booklet of the same title issued in March 2015.
The update to this product is in response to the CFPB’s Press Release entitled “Bureau of Consumer Financial Protection Issues Updated FCRA Model Disclosures” dated 09/12/18 that issued an interim final rule updating two model disclosures to reflect changes made to the Fair Credit Reporting Act (FCRA) by recent legislation that are included in the purchase price of the Fair Credit Reporting Act Policy Template.
The update to these products is in response to OCC Bulletin 2018-26 dated 09/12/18 that announced the availability of a revised “Other Real Estate Owned” booklet of the Comptroller’s Handbook, which provides guidance on the acquisition, reporting, management, and disposition of other real estate owned (OREO). The updated booklet includes accounting changes for foreclosed property under contract, in accordance with the Financial Accounting Standards Board’s Accounting Standards Codification Subtopic 360-20, Subtopic 610-20, and Topic 606. Other updates were made to the booklet, as summarized in the “Highlights” section of this OCC Bulletin and in the “Table of Updates Since Publication” section of the OREO booklet.
The update to this product is in response to the Federal Reserve Board’s Press Release entitled “Federal Reserve Board Approves Final Amendments to Liability Provisions of Regulation CC” dated 09/12/18 that approved final amendments to the liability provisions of Regulation CC, which governs availability of funds and collection of checks. These amendments continue the Federal Reserve Board’s efforts to update Regulation CC to reflect the evolution of the nation’s check collection system from one that is largely paper-based to one that is virtually all electronic. The amendments become effective January 1, 2019.