Product Updates September 2026
The Product Updates for September 2026 from BankPolicies.com feature the following revised policy and form template products:
Asset, Liability, and Liquidity Management Policy Template
Brokered Deposits Policy Template
The update to these products is in response to FDIC FIL-52-2026 entitled “Interim Final Rule on Reciprocal Deposits” dated 08/27/26 that announced an adoption of an interim final rule to implement section 902 of the 21st Century ROAD to Housing Act (the Housing Act), which amended the statutory framework governing reciprocal deposits, and to provide clarifications regarding the operation of the reciprocal deposits framework. In general, the interim final rule:
- Amends the FDIC’s brokered deposit regulations concerning the limited exception for reciprocal deposits to conform to section 29 of the Federal Deposit Insurance Act, as amended by section 902 of the Housing Act;
- Increases the amount of reciprocal deposits agent institutions may exclude from treatment as brokered deposits by modifying the “general cap” with a new tiered liability-based calculation, up to a maximum of $30 billion;
- Amends the definition of “agent institution” to include 3-rated, well capitalized institutions;
- Clarifies when an institution “receives” nonmaturity reciprocal deposits;
- Clarifies when an institution requalifies as an agent institution following a supervisory rating change, capital-category change, approval of a brokered deposits waiver, or a reduction in reciprocal deposits below its “special cap;” and
- Outlines coordination with the Federal Financial Institutions Examination Council (FFIEC) to update Call Report instructions.
Bank Secrecy Act Policy Template – Basic Version
Bank Secrecy Act Policy Template – Comprehensive Version
The update to these products is in response to Joint Release entitled “Joint Statement on Suspicious Activity Report Confidentiality Considerations Regarding Communications with Customers” dated 09/02/26 that clarifies confidentiality requirements related to Suspicious Activity Reports (SARs), particularly when banks communicate with their customers regarding potentially fraudulent transactions, other suspicious activity (e.g., payment fraud, including check fraud), or account closures.
BSA Suspicious Activity Report Notices Template
The update to this product is in response to:
- FinCEN Alert FIN-2026-Alert005 entitled “FinCEN Alert on Money Laundering Activity Associated with Digital Asset Investment Scam Centers” dated 09/03/26 that urge financial institutions to be vigilant in detecting, identifying, and reporting suspicious activity connected to the operation of digital asset investment scam centers and the laundering of associated illicit proceeds. Transnational criminal organizations (TCOs)—predominantly in Southeast Asia—operate these scam centers, which target individuals, including numerous Americans, with digital asset investment scams and other fraud schemes. A vast illicit ecosystem, which includes online marketplaces for cybercrime and money laundering-related services and artificial intelligence-supported software platforms, enables scam centers’ operations.
- FinCEN Alert FIN-2026-Alert006 entitled “FinCEN Alert to Counter Iranian Procurement Efforts for its Commercial Aviation Industry” dated 09/08/26 to assist financial institutions in identifying and reporting procurement networks supporting Iran’s aviation industry. This Alert supports Operation Economic Outcast, the Trump Administration’s campaign to sever the economic lifelines that sustain the Iranian regime and the Islamic Revolutionary Guard Corps (IRGC).
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