Product Updates for September 2018
The Product Updates for September 2018 from BankPolicies.com feature the following new and revised policy template products:
The update to these products is in response to FinCEN Advisory FIN-2018-R003 entitled “Extension of Limited Exception from Beneficial Ownership Requirements for Legal Entity Customers of Certain Financial Products and Services with Rollovers and Renewals” dated 08/08/18 that extends the limited exception for an additional 30 days, up to and including September 8, 2018, from the obligations of the Beneficial Ownership Rule for rollover or renewal of certain financial products and services (i.e., certificate of deposit or loan accounts) that were established before May 11, 2018 to further consider the issue.
The update to these products is in response to the FDIC’s FIL-42-2018 entitled “Modifications to the Statement of Policy for Section 19 of the Federal Deposit Insurance Act” dated 08/20/18 that modifies its Statement of Policy (SOP) for Section 19 of the Federal Deposit Insurance (FDI) Act. Section 19 prohibits, without the prior written consent of the FDIC, a person convicted of any criminal offense involving dishonesty, breach of trust, money laundering, or who has entered into a pretrial diversion or similar program (program entry) in connection with a prosecution for such offense, from participating in the affairs of an FDIC-insured institution. The modifications are expected to reduce the number of Section 19 applications and regulatory burden and was published in the Federal Register on August 3, 2018.
The update to this product is in response to the CFPB’s Press Release entitled “Bureau of Consumer Financial Protection Updates Regulation P to Implement Legislation Amending Gramm-Leach-Bliley Act” dated 08/10/18 that finalized amendments to implement legislation that allows financial institutions that meet certain requirements to be exempt from sending annual privacy notices to their customers.
The update to this product is in response to the CFPB’s publication in the Federal Register entitled “Truth in Lending (Regulation Z) Annual Threshold Adjustments (Credit Cards, HOEPA, and Qualified Mortgages)” dated 08/27/18 that issued a final rule amending the regulation text and official interpretations for Regulation Z, which implements the Truth in Lending Act (TILA). The CFPB is required to calculate annually the dollar amounts for several provisions in Regulation Z; this final rule revises, as applicable, the dollar amounts for provisions implementing TILA and amendments to TILA, including under the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act), the Home Ownership and Equity Protection Act of 1994 (HOEPA), and the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The CFPB is adjusting these amounts, where appropriate, based on the annual percentage change reflected in the Consumer Price Index (CPI) in effect on June 1, 2018. The changes are effective January 1, 2019.