Product Updates for October 2024
The Product Updates for October 2024 from BankPolicies.com feature the following revised policy template products:
Bank Secrecy Act Policy Template – Comprehensive Version
Office of Foreign Assets Control Policy Template
The update to these products is in response to OFAC’s final rule entitled “Reporting, Procedures and Penalties Regulations” dated 10/07/24 that amends the Reporting, Procedures and Penalties Regulations (the “Regulations”). OFAC issued an interim final rule with a request for comments on May 10, 2024 (“May 2024 Interim Final Rule”). In this final rule, OFAC responds to public comments submitted in response to the May 2024 Interim Final Rule and amends the Regulations to add three exceptions to the reporting requirement for any blocked property that is unblocked or transferred. The final rule is effective 30 days after publication in the Federal Register.
Commercial Loan Policy Template
Commercial Real Estate Loan Policy Template
The update to these products is in response to OCC Bulletin 2024-29 entitled “Commercial Lending: Refinance Risk” dated 10/03/24 that provides guidance for managing credit risk associated with refinance risk. The bulletin discusses the effect of refinance risk on credit risk in commercial loan transactions and portfolios, and provides guidance on transaction and portfolio-level refinance risk management.
Information Systems Security Policy Template
Internet Banking Policy Template
The update to these products is in response to the FFIEC’s Statement entitled “CAT Sunset Statement” dated 08/29/24 that announced on behalf of the agencies that they will sunset the Cybersecurity Assessment Tool (CAT) on August 31, 2025. The CAT was released in June 2015 as a voluntary assessment tool to help financial institutions identify their risks and determine their cybersecurity preparedness. While the fundamental security controls addressed throughout the maturity levels of the CAT are sound, several new and updated government and industry resources are available that financial institutions can leverage to better manage cybersecurity risks.
Development, Acquisition, and Maintenance Policy Template
Information Systems Security Policy Template
The update to these products is in response to the FFIEC’s revised and renamed Development and Acquisition booklet to Development, Acquisition, and Maintenance (DA&M) to reflect the changing technological environment and increasing need for security and resilience, including developmental design, acquisition and procurement, and maintenance and change control processes for information technology systems. In addition, the booklet provides fundamental examination expectations regarding developmental quality controls, acquisition and procurement planning and execution, governance and risk management, and maintenance and change control practices of entities.
NOTE: Clients who have purchased our Information Systems Security Policy Template which is covered by a Product Update Protection Plan still in effect on 10/01/24 will automatically receive the updated Development, Acquisition, and Maintenance Policy Template (formerly entitled “Systems Development and Acquisition Policy Template”) as a free upgrade since we removed this topic from the Information Systems Security Policy Template due to the size of the guidance. In addition, your Product Update Protection Plan will cover the Development, Acquisition, and Maintenance Policy Template for any future updates we issue to that product.
The update to this product is in response to the Federal Reserve’s Final Rule entitled “Regulation A: Extensions of Credit by Federal Reserve Bank” dated 09/25/24 that announced final amendments to its regulations to reflect the Federal Reserve Board’s approval of a decrease increase 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 September 25, 2024. The rate changes for primary and secondary credit were applicable on September 19, 2024.
The update to this product is in response to the Federal Reserve’s Final Rule entitled “Regulation D: Reserve Requirements of Financial Institutions” dated 09/25/24 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 4.90 percent, a 0.50 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 September 25, 2024. The IORB rate change was applicable on September 19, 2024.
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