Product Updates for September 2020
The Product Updates for September 2020 from BankPolicies.com feature the following revised policy template products:
These new and updated products are in response to client requests for us to create a policy template in relation to the SEC’s “Regulation Best Interest” which established a new standard of conduct under the Securities Exchange Act of 1934 for broker-dealers and natural persons who are associated persons of a broker-dealer when making a recommendation of any securities transaction or investment strategy involving securities (including account recommendations) to a retail customer. The effective date for Regulation Best Interest is September 10, 2019, whereas the compliance date is June 30, 2020. If your financial institution participates in the sale of Non-Deposit Investment Products (NDIPs), your auditors will be asking for your Regulation Best Interest Policy.
Your comments and ideas are always greatly appreciated and will be taken into consideration whenever we revise our current products or create new ones. In summary, we want to ensure your success and earn your business!
The update to these products is in response to the “Joint Statement on Bank Secrecy Act Due Diligence Requirements for Customers Who May Be Considered Politically Exposes Persons” dated 08/21/20 that addresses due diligence questions raised by banks related to Bank Secrecy Act/Anti-Money Laundering (BSA/AML) regulatory requirements for customers whom banks may consider to be politically exposed persons (PEPs). Banks have requested clarification on how to apply a risk-based approach to PEPs consistent with the customer due diligence (CDD) requirements contained in FinCEN’s 2016 CDD Final Rule.
As a reminder, the complete contents of the Customer Identification Program Policy Template are included as Topic 7 within the Bank Secrecy Act Policy Template – Comprehensive Version.
The update to these products is in response to OFAC’s Interim Final Rule entitled “Inflation Adjustment of Civil Monetary Penalties Related to Reporting and Recordkeeping” dated 09/02/20 that adjusts for inflation its civil monetary penalties for failure to comply with certain recordkeeping and reporting requirements, which are contained in OFAC’s Economic Sanctions Enforcement Guidelines in OFAC’s Reporting, Procedures and Penalties Regulations. The rule is effective October 5, 2020.
As a reminder, the complete contents of the Office of Foreign Assets Control Policy Template are included as Topic 19 within the Bank Secrecy Act Policy Template – Comprehensive Version.
The update to this product is in response to the Joint Press Release entitled “Agencies Issue Three Final Rules” dated 08/26/20 that finalized a final rule that gives eligible institutions the option to mitigate the estimated capital effects of CECL for two years, followed by a three-year transition period. Taken together, these measures offer institutions a transition period of up to five years. In a change from the interim rule, the final rule expands the pool of eligible institutions to include any institution adopting CECL in 2020. The CECL final rule is effective immediately upon publication in the Federal Register.
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