Product Updates September 2017

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

Revised Policy Templates

Bank Secrecy Act Policy Template – Basic Version
Bank Secrecy Act Policy Template – Comprehensive Version

The update to these products is in response to FinCEN’s Advisory FIN-2017-A003 entitled “Advisory to Financial Institutions and Real Estate Firms and Professionals” dated 08/22/17 that provides financial institutions and the real estate industry with information on the money laundering risks associated with real estate transactions, including those involving luxury property purchased through shell companies, particularly when conducted without traditional financing.


Overdraft Policy Template

The update to this product is in response to the Federal Reserve’s Policy Statement dated 08/25/17 that revised part II of the Federal Reserve Policy on Payment System Risk (PSR policy) related to the transaction posting times used for measuring balances intraday in institutions’ accounts at the Federal Reserve Banks (Reserve Banks) to conform to enhancements to the Reserve Banks’ same-day automated clearinghouse (ACH) service.  The effective date is September 15, 2017.


Regulation C Policy Template

The update to this product is in response to the CFPB’s Final Rule entitled “Home Mortgage Disclosure Act (Regulation C), Final Rule” dated 08/24/17 that amends Regulation C to make technical corrections to and to clarify certain requirements adopted by the CFPB’s Home Mortgage Disclosure (Regulation C) final rule (2015 HMDA Final Rule or the Final Rule), which was published in the Federal Register on October 28, 2015.  In addition, the CFPB is amending Regulation C to increase the threshold for collecting and reporting data about open-end lines of credit for a period of two years so that financial institutions originating fewer than 500 open-end lines of credit in either of the preceding two years would not be required to begin collecting such data until January 1, 2020.  Furthermore, the CFPB is adopting a new reporting exclusion.


Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) Policy Template

The update to this product is in response to the CFPB’s Compliance Bulletin 2017-01 entitled “Phone Pay Fees” dated 08/02/17 that warns companies about tricking consumers into expensive pay-by-phone fees.  The CFPB is concerned about companies potentially misleading consumers about the purpose and amount of certain pay-by-phone fees or keeping them in the dark about much cheaper payment options.  The bulletin also reviews guidelines to help consumer financial companies comply with the law.