Product Updates October 2021

Product Update Blog

Product Updates for October 2021

The Product Updates for October 2021 from feature the following new and revised policy template products:

Earnings Policy Template – NEW!

This new product was developed in response to OCC Bulletin 2021-44 entitled “Comptroller’s Handbook: Revised Earnings and Regulatory Reporting Booklets” dated 09/22/21 that announced the issuance of a new “Earnings” booklet that:

  • Supplements the earnings core assessments and provides examiners with expanded procedures to use when reviewing earnings for a specific line of business or the bank as a whole.
  • Provides information regarding how to complete an earnings analysis, highlights key earnings ratios and the components that make up those ratios, and discusses other factors to consider when reviewing a bank’s earnings performance.
  • Discusses sound risk management principles, including appropriate planning, budgeting, and forecasting processes, to ensure that earnings are sufficient to maintain adequate capital and reserves.

Human Resources Vaccination Policy Template – NEW!

Human Resources General Policy Template

These new and updated products are in response to client requests who submitted their suggestions to our “Client Wish List” that we develop a policy regarding vaccinations in relation to COVID-19, annual influenza, and other preventive immunizations.

The complete contents of the new Human Resources Vaccination Policy Template are included as Topic 29 within the Human Resources General Policy Template.

Automated Clearing House Policy Template

The update to this product is in response to the following NACHA final rules:

  • Addressing the existing practice of Nested Third-Party Sender relationships, and
  • Making explicit and clarifying the requirement that a TPS conduct a Risk Assessment.

The two rules are effective 09/30/22, with a 6-month grace period for certain aspects of each rule.

  • Minor Rules Topics” dated 09/17/21 that amend the NACHA Operating Rules (Rules) to address a variety of minor topics related to Meaningful Modernization, an ACH Operator edit and expiration of stop payments on non-consumer accounts.

Bank Secrecy Act Policy Template – Comprehensive Version

The update to this product is in response to the FinCEN Notice FIN-2021-NTC3 entitled “FinCEN Calls Attention to Online Child Sexual Exploitation Crimes” dated 09/16/21 that calls attention to an increase in online child sexual exploitation (OCSE) crimes.  This Notice highlights some financial trends related to OCSE, and provides financial institutions with specific suspicious activity report (SAR) filing instructions.

Commercial Loan Policy Template

Small Business Administration Loan Policy Template

The update to these products is in response to SBA Administrator Isabella Casillas Guzman’s announcement of major enhancements to the COVID Economic Injury Disaster Loan (EIDL) program, a federal disaster relief loan designed to better serve and support small business communities still reeling from the pandemic, especially hard-hit sectors such as restaurants, gyms, and hotels.  The SBA is ready to receive new applications immediately from small businesses looking to take advantage of these new policy changes.

As a reminder, the complete contents of the Small Business Administration Loan Policy Template are included as Topic 19 within the Commercial Loan Policy Template.

Keeping You Informed

We provide this Product Update Blog as a courtesy to all clients regarding new and revised products released by  We feel that it is important to keep our clients well informed of changes to the financial institution industry, including keeping on top of federal regulatory changes, and industry recommended best practices.  In this regard, we encourage you to subscribe to our newsletter in which these types of announcements are made including any special offers that can save you time and money.  Just contact us to be added to our distribution list.

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