Product Updates October 2026
The Product Updates for October 2026 from BankPolicies.com feature the following revised policy template product:
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 dated 09/25/26 that added the Sanctions Penalties Regulations. These new regulations consolidate previously existing information regarding penalties applicable to multiple sanctions programs implemented by OFAC. This rule is effective upon publication in the Federal Register.
BSA Suspicious Activity Report Notices Template
The update to this product is in response to FinCEN Alert FIN-2026-Alert007 entitled “FinCEN Alert on the A7 Network” dated 10/01/26 that urges financial institutions to be vigilant in detecting, identifying, and reporting suspicious activity, including involving the A7 Network. The A7 Network is a global wholesale sanctions evasion and money laundering service with ties to Russia, leveraged by a wide range of illicit actors, including Iran and its terrorist proxies. The A7 Network’s well-established and far-reaching digital asset channels are an appealing tool for a wide range of threat actors. Analysis of BSA data also indicates that Iranian actors are leveraging the A7 Network, including the Central Bank of Iran and Iran’s Islamic Revolutionary Guard Corps (IRGC).
Concentrations of Credit Policy Template
The update to this product is in response to OCC Bulletin 2026-49 entitled “Concentrations of Credit: Revised Comptroller’s Handbook Booklet and Rescissions” dated 09/30/26 that announced version 3.0 of the “Concentrations of Credit” booklet of the Comptroller’s Handbook. This booklet replaces version 2.0 of the booklet of the same title. Also rescinded is OCC Bulletin 2020-90, “Concentrations of Credit: Revised Comptroller’s Handbook Booklet and Rescissions,” which transmitted version 2.0 of the booklet.
The update to this product is in response to the Federal Reserve’s Final Rule entitled “Regulation A: Extensions of Credit by Federal Reserve Banks” dated 09/30/26 that announced final amendments to its regulations to reflect the Federal Reserve Board’s approval of a decrease in the rate for primary credit at each Federal Reserve Bank. The secondary credit rate at each Reserve Bank automatically increased by formula as a result of the Board’s primary credit rate action.
The amendments to part 201 (Regulation A) are effective 09/30/26. The rate changes for primary and secondary credit were applicable on 09/17/26.
The update to this product is in response to the Federal Reserve’s Final Rule entitled “Regulation D: Reserve Requirements of Financial Institutions” dated 09/30/26 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 3.90 percent, a 0.25 percentage point increase 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 09/30/26. The IORB rate change was applicable on 09/17/26.
Vendor Management Program Policy Template
The update to this product is in response to the “Joint Statement on Community Banks’ Engagement with Core Service Providers” dated 09/11/26 that provides clarity on their risk-based supervision of certain services provided to community banking organizations (CBOs).
The agencies believe there is a need for additional clarification regarding a subset of CBOs’ third-party relationships, based on the agencies’ supervision of CBOs and their service providers, and reinforced by the agencies’ outreach to CBOs and other relevant stakeholders. This subset consists of third-parties that provide the critical systems applications and infrastructure that support the operation and essential functions of one or more of a CBO’s lines of business, including, for example, through the provision of transaction processing, account management, payments processing, customer relationship management, compliance and reporting, online banking, and other material functions. For purposes of this statement, the agencies refer to these entities broadly as core providers. These relationships are essential to the safe and sound operations of CBOs, yet certain core provider business practices and market dynamics may pose obstacles to a CBO’s ability to efficiently and effectively identify, assess, and address the attendant risks.
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