Product Updates September 2022

Product Update Blog

Product Updates for September 2022

The Product Updates for September 2022 from feature the following new and revised policy template products:

Access to Accounts and Services at Federal Reserve Banks Policy Template – NEW!

This new product was created in response to the Federal Reserve Bank’s Press Release entitled “Federal Reserve Board Announces Final Guidelines that Establish a Transparent, Risk-Based, and Consistent Set of Factors for Reserve Banks to Use in Reviewing Requests to Access Federal Reserve Accounts and Payment Services” dated 08/15/22.  The final guidelines are substantially similar to those proposed by the Federal Reserve Board in its May 2021 proposal and March 2022 supplemental proposal.  The new guidelines will be effective upon publication in the Federal Register.

Capital Planning Program Policy Template

Corporate Governance Policy Template

The update to these products is in response to the revised FDIC’s “Risk Management Manual of Examination Policies” (RMS Manual) dated 08/29/22 regarding updates to Section 2.1 that includes a new capital planning section and revised instructions to accommodate financial institutions that have adopted the Current Expected Credit Losses (CECL) methodology or the Community Bank Leverage Ratio (CBLR) capital framework.

Commercial Real Estate Loan Policy Template

Consumer Loan Policy Template

Current Expected Credit Losses Policy Template

General Loan Policy Template

Loan Workout Policy Template

Non-Accrual and Charged-Off Loan Policy Template

The update to these products is in response to the OCC Bulletin 2022-20 entitled “Accounting: Bank Advisory Series Updated” dated 08/15/22 that announced an update to the Bank Accounting Advisory Series (BAAS).  Most notably, the update incorporates Accounting Standards Update (ASU) 2022-02, “Financial Instruments – Credit Losses (Topic 326): Troubled Debt Restructurings and Vintage Disclosures” issued by the FASB on March 31, 2022.  In general, ASU 2022-02 eliminates the accounting guidance for troubled debt restructurings (TDRs) by creditors that have adopted Accounting Standards Codification (ASC) Topic 326 and enhances disclosures for certain loan refinancings and restructurings when a borrower is experiencing financial difficulty.  In addition, the BAAS contains staff responses to frequently asked questions from the banking industry and bank examiners on a variety of accounting topics and promotes consistent application of accounting standards and regulatory reporting among banks.

This bulletin rescinds OCC Bulletin 2021-37, “Accounting: Bank Accounting Advisory Series Updated,” which conveyed the 2021 edition of the BAAS.

Compliance Management Policy Template

The update to this product is in response to OCC Bulletin 2022-21 entitled “Information Security: Expectations for Protecting Non-Public OCC Information on Institution- or Other Non-OCC-Owned or Managed Video Teleconferencing Services” dated 09/07/22 that explains the OCC’s expectations for protecting non-public OCC information, as defined in 12 CFR 4.32(b)(1), shared on video teleconferencing services that are operated or managed by an institution or any other party.  Video teleconferencing (VTC) services provide collaboration capabilities that allow communication via internet-enabled text, voice, and video and can allow the sharing of files and other content.  VTC services are a key enabler for OCC supervisory activities.  This bulletin describes the security provisions designed to protect non-public OCC information from disclosure that need to be in place for OCC personnel to join meetings hosted on institution- or other non-OCC-operated or managed VTC services in which such information is expected to be communicated.

Cryptocurrency Policy Template

The update to this product is in response to the Federal Reserve’s Press Release entitled “Engagement in Crypto-Asset-Related Activities by Federal Reserve-Supervised Banking Organizations” dated 08/16/22 that provided additional information for banking organizations engaging or seeking to engage in crypto-asset-related activities.  In general, the supervisory letter outlines the steps Federal Reserve Board-supervised banks should take prior to engaging in crypto-asset-related activities, such as assessing whether such activities are legally permissible and determining whether any regulatory filings are required.  Additionally, the supervisory letter states that Federal Reserve Board-supervised banking organizations should notify the Federal Reserve Board prior to engaging in crypto-asset-related activities.  The supervisory letter also emphasizes that Federal Reserve Board-supervised banking organizations should have adequate systems and controls in place to conduct crypto-asset-related activities in a safe and sound manner prior to commencing such activities.

Keeping You Informed

We provide this Product Update Blog as a courtesy to all clients regarding new and revised products released by  We feel that it is important to keep our clients well informed of changes to the financial institution industry, including keeping on top of federal regulatory changes, and industry recommended best practices.  In this regard, we encourage you to subscribe to our newsletter in which these types of announcements are made including any special offers that can save you time and money.  Just contact us to be added to our distribution list.

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