Product Updates for October 2021
The Product Updates for October 2021 from BankPolicies.com 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.
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 update to this product is in response to the following NACHA final rules:
- “Third-Party Roles and Responsibilities” dated 09/30/21 that clarify the roles and responsibilities of Third-Party Senders (TPS) in the ACH Network by:
- 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.
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.
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
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