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Product Updates September 2019

Product Updates for September 2019

The Product Updates for September 2019 from BankPolicies.com feature the following revised policy template products:

Audit Policy Template

The update to this product is in response to OCC Bulletin 2019-38 entitled “Revised Updated Booklets and Rescissions” dated 07/25/19 that announced the issuance of an updated “Internal and External Audits” booklet of the Comptroller’s Handbook. The new booklet replaces the booklet of the same title issued in 2016 and rescind the following: OCC Bulletin 2016-47, “Internal and External Audits: Revised Comptroller’s Handbook Booklet and Rescissions.” The revised booklet:

  • Reflects relevant OCC issuances published since the booklet was last issued;
  • Reflects the integration of federal savings associations into certain regulations;
  • Includes clarifying edits regarding supervisory guidance, sound risk management practices, or legal language;
  • Clarifies the duties and responsibilities of the bank’s board and management. The board is responsible for overseeing the activities of a bank, and management is responsible for implementing the appropriate actions;
  • Revises and reorganizes certain content for general clarity; and
  • Certain sections of the examination procedures were removed and replaced with cross-references to more comprehensive examination procedures in other booklets.

Corporate Governance Policy Template
Enterprise-Wide Risk Management Program Policy Template
Management Succession Plan Policy Template
Strategic Plan Policy Template

The update to these products is in response to OCC Bulletin 2019-38 entitled “Revised Updated Booklets and Rescissions” dated 07/25/19 that announced the issuance of a fully revised “Corporate and Risk Governance” booklet of the Comptroller’s Handbook. The new booklet replaces the booklet of the same titles issued in 2016 and rescind the following: OCC Bulletin 2016-25, “Corporate and Risk Governance: New Comptroller’s Handbook Booklet and Rescissions.” The updated booklet:

  • Reflects relevant OCC issuances published since the booklet was last issued;
  • Reflects the integration of federal savings associations into certain regulations;
  • Includes clarifying edits regarding supervisory guidance, sound risk management practices, or legal language;
  • Clarifies the duties and responsibilities of the bank’s board and management. The board is responsible for overseeing the activities of a bank, and management is responsible for implementing the appropriate actions;
  • Revises and reorganizes certain content for general clarity; and
  • Certain sections of the examination procedures were removed and replaced with cross-references to more comprehensive examination procedures in other booklets.

As a reminder, the completed contents of the Enterprise-Wide Risk Management Program Policy Template, Management Succession Plan Policy Template, and Strategic Plan Policy Template are included within the Corporate Governance Policy Template as topics 27, 5, and 14 respectively.


Regulation A Policy Template

The update to this product is in response to the Federal Reserve’s Final Rule issued on 08/12/19 that adopted final amendments to its Regulation A to reflect the Federal Reserve Board’s approval of an increase 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 Federal Reserve Board’s primary credit rate action.


Regulation CC Policy Template

The update to this product is in response to the Federal Reserve’s Final Rule dated 08/29/19 that corrects errors in amendatory instructions affecting the final rule published in the Federal Register on July 3, 2019 which amended Regulation CC, which implements the Expedited Funds Availability Act (EFA Act), to implement a statutory requirement in the EFA Act to adjust the dollar amounts under the EFA Act for inflation, incorporate the Economic Growth, Regulatory Relief, and Consumer Protection Act, and made certain other technical amendments.

In addition, we revised this product to eliminate any regulatory guidance that was in effect prior to the rules that went into effect on 09/03/19.


Regulation D Policy Template

The update to this product is in response to the Federal Reserve’s Final Rule issued on 08/12/19 that revises the rate of interest paid on balances maintained to satisfy reserve balance requirements (“IORR”) and the rate of interest paid on excess balances (“IOER”) maintained at Federal Reserve Banks by or on behalf of eligible institutions. The final amendments specify that IORR is 2.10 percent and IOER is 2.10 percent, a 0.25 percentage point increase from their prior levels.


Regulation Z Policy Template

The update to this product is in response to the CFPB’s Final Rule entitled “Truth in Lending (Regulation Z) Annual Threshold Adjustments (Credit Card, HOEPA, and Qualified Mortgages)” dated 08/01/19 that amends the 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, and this final rule reviews 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).


Keeping You Informed

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