Product Updates September 2015 is providing you with these product updates as a courtesy to all of our clients. If you have any questions, please contact us.

New and Revised Policy Templates

Tax Refund Product Policy TemplateNEW!

This new product was developed in response to the OCC’s Bulletin 2015-36 entitled “Tax Refund Related Products” dated 08/04/15 that provides guidance to outline safety and soundness measures that banks should follow if they offer tax refund related products.

Homeowners Protection Act Policy Template

The update to this product is in response to the CFPB’s Bulletin 2015-03 entitled “Private Mortgage Insurance Cancelation and Termination” dated 08/04/15 that provides guidance to assist residential mortgage servicers and subservicers in their compliance with the private mortgage insurance (PMI) cancellation and termination provisions of the Homeowners Protection Act of 1998 (HPA). This compliance bulletin explains HPA requirements and describes examples from CFPB’s supervisory experience of PMI cancellation and termination procedures that violate the HPA or create a substantial risk of noncompliance.