Product Updates September 2025
The Product Updates for September 2025 from BankPolicies.com feature the following revised policy and form template products:
Bank Secrecy Act Policy Template – Basic Version
Bank Secrecy Act Policy Template – Comprehensive Version
The update to these products is in response to FinCEN’s guidance entitled “Cross-Border Information Sharing by Financial Institutions and SAR Confidentiality” dated 09/05/25 that encourages and promotes appropriate, voluntary cross-border sharing of information between and among financial institutions, including appropriate foreign financial institutions, to help combat the threats posed by money laundering, terrorist financing, and other illicit finance activity, including from drug trafficking organizations (DTOs), foreign terrorist organizations (FTOs), and fraudsters. This guidance seeks to:
- Clarify that the Bank Secrecy Act and its implementing regulations (collectively, the “BSA”) generally do not prohibit cross-border information sharing; and
- Provide examples of information that typically would not reveal the existence of a Suspicious Activity Report (SAR) and, thus, that the BSA does not prohibit sharing.
BSA Suspicious Activity Report Notices Template
The update to this product is in response to FinCEN Advisory FIN-2025-A003 entitled “FinCEN Advisory on the Use of Chinese Money Laundering Networks by Mexico-Based Transnational Criminal Organizations to Launder Illicit Proceeds” dated 08/28/25 to urge financial institutions to be vigilant in identifying and reporting suspicious transactions potentially related to the use of Chinese money laundering networks (CMLNs) by the Jalisco New Generation Cartel (CJNG), the Sinaloa Cartel, the Gulf Cartel, and other Mexico-based transnational criminal organizations (TCOs)—frequently known collectively as the “Cartels”—to launder illicit proceeds. CMLNs are considered professional money launderers (PMLs) and play a vital role in laundering the Cartels’ drug proceeds in the United States.
As a reminder, the BSA Suspicious Activity Report Notices Template is included in the purchase price of the Bank Secrecy Act Policy Template – Comprehensive Version.
Fair Credit Reporting Act Policy Template
The update to this product is in response to:
- The Homebuyers Privacy Protection Act (H.R. 2808), which generally prohibits credit reporting firms from selling mortgage applicant information to lenders who then assail those same consumers with unwanted solicitations. The Act amends section 604(c) of the Fair Credit Reporting Act to eliminate abusive mortgage “trigger leads,” only allowing contact information to be sold to third parties under limited circumstances. The act is effective March 4, 2026.
- A federal court in Texas vacated the rule “Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V)” on 07/11/25 which had been finalized in January 2025 and aimed to remove medical debt from credit reports. The court ruled that the CFPB exceeded its authority under the Fair Credit Reporting Act (FCRA) by prohibiting the reporting of medical debt, a practice the FCRA permits when the debt is properly coded to protect patient privacy. In addition, the ruling found that the FCRA preempts state laws that attempt to ban medical debt reporting.
The update to this product is in response to:
- The Federal Reserve’s FedPayments Improvement group’s release of two new toolkits to support education and increase awareness concerning check fraud. These new toolkits, Scams Mitigation Toolkit and Check Fraud Mitigation Toolkit, are designed to help financial institutions and the payments industry to better identify and fight fraud and scams. This comprehensive policy update is essential for any financial institution’s program to help combat fraud.
- Release of the Consumer Compliance Outlook (Second Issue 2025) that includes a special fraud issue. While technology has facilitated many common fraudulent schemes (such as social media scams, text messaging scams, and phishing e-mails), it is also providing ways to combat fraud. Through advances in technology, private companies are developing sophisticated tools to identify and block fraudulent transactions. This special issue discusses several fraud topics, including the banking agencies’ recent request for information on payment and check fraud.
- Release of the article entitled “Payment Security – What’s New with Account Fraud” to financial institutions about how new account fraud is carried out, how it has evolved significantly, and how to better safeguard secure digital account openings.
The update to these products is in response to the repeal on 05/08/25 of the CFPB’s final rule entitled “Overdraft Lending: Very Large Financial Institutions” dated 12/12/24 that amends Regulations E and Z to update regulatory exceptions for overdraft credit provided by very large financial institutions.
The update to this product is in response to the vacated ruling on 04/14/25 of the CFPB’s final rule entitled “Credit Card Penalty Fees Final Rule” dated 03/05/24 that amends Regulation Z, which implements the Truth in Lending Act (TILA), to address late fees charged by card issuers that together with their affiliates have one million or more open credit card accounts (referred to as “Larger Card Issuers” herein).
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