Product Updates for September 2024
The Product Updates for September 2024 from BankPolicies.com feature the following revised policy template products:
Bank Secrecy Act Policy Template – Comprehensive Version
The update to this product is in response to the following final rules issued by FinCEN:
- “Anti-Money Laundering Regulations for Residential Real Estate Transfers” dated 08/28/24 that requires certain persons involved in real estate closings and settlements to submit reports and keep records on certain non-financed transfers of residential real property to specified legal entities and trusts on a nationwide basis. Transfers made directly to an individual are not covered by this rule. This rule describes the circumstances in which a report must be filed, who must file a report, what information must be provided, and when a report is due. The final rule is effective 12/01/25.
- “Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Reporting Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers” dated 08/28/24 that includes certain investment advisers in the definition of “financial institution” under the Bank Secrecy Act (BSA), prescribe minimum standards for anti-money laundering/countering the financing of terrorism (AML/CFT) programs to be established by certain investment advisers, require certain investment advisers to report suspicious activity to FinCEN pursuant to the BSA, and make several other related changes to FinCEN regulations. These regulations will apply to certain investment advisers who may be at risk for misuse by money launderers, terrorist financers, or other actors who seek access to the U.S. financial system for illicit purposes and who threaten U.S. national security. The final rule is effective 01/01/26.
Bank Secrecy Act Policy Template – Comprehensive Version
Office of Foreign Assets Control Policy Template
The update to these products is in response to OFAC’s interim final rule entitled “Reporting, Procedures and Penalties” dated 09/11/24 that announced an interim final rule to amend the Reporting, Procedures and Penalties Regulations (the “Regulations”), extending recordkeeping requirements for certain transactions from five to 10 years, consistent with the statute of limitations for violations of certain sanctions administered by the Office of Foreign Assets Control (OFAC). This interim final rule is effective 180 days after date of publication in the Federal Register.
Compliance Management Policy Template
The update to these products is in response to the Federal Reserve’s Consumer Compliance Outlook (Second Issue 2024) that underscores the importance of a complaint management program in an effective compliance management system (CMS).
Unfair or Deceptive Acts or Practices (UDAP) Policy Template
The update to this product is in response to the FTC’s final rule entitled “Trade Regulation Rule on the Use of Consumer Reviews and Testimonials” dated 08/15/24 that announces a final rule and Statement of Basis and Purpose (“SBP”) relating to certain specified unfair or deceptive acts or practices involving consumer reviews or testimonials. This final rule, among other things, prohibits selling or purchasing fake consumer reviews or testimonials, buying positive or negative consumer reviews, certain insiders creating consumer reviews or testimonials without clearly disclosing their relationships, creating a company-controlled review website that falsely purports to provide independent reviews, certain review suppression practices, and selling or purchasing fake indicators of social media influence.
The final rule is effective 60 days after date of publication in the Federal Register.
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