ALM, BSA, Investment, Reg D and Z Updates

Product Update Notification - 06/22/09

Revised Asset, Liability and Liquidity Management Policy Template

Asset, Liability and Liquidity Management Policy Template

The update to this product was in response to the FDIC's FIL-25-2009 that announced a final rule that makes certain revisions to the interest rate restrictions under Part 337.6 of the FDIC Rules and Regulations. Under the final rule, the "national rate" is a simple average of rates paid by U.S. depository institutions as calculated by the FDIC.

http://www.fdic.gov/news/news/financial/2009/fil09025.html

Revised Bank Secrecy Act Policy Template

Bank Secrecy Act Policy Template

The update to this product was in response to FinCEN's guidance:

Letter FIN-2009-G001 that assists banks in determining the appropriateness of exempting non-listed business customers that derive some portion of their annual gross revenues from ineligible business activities from currency transaction reporting requirements.

http://www.fincen.gov/statutes_regs/guidance/html/fin-2009-g001.html

Release that clarifies the use of an important information sharing tool made possible by section 314(b) of the USA PATRIOT Act.

http://www.fincen.gov/news_room/nr/html/20090616.html

Revised Consumer Loan Policy Template

Revised Servicemembers Civil Relief Act Policy Template

Consumer Loan Policy Template

Servicemembers Civil Relief Act Policy Template

The update to these products is in response to the Federal Reserve Consumer Affairs Letter CA 09-2 dated March 24, 2009 that announces interagency examination procedures for determining a financial institution's compliance with the Servicemembers Civil Relief Act (SCRA).

http://www.federalreserve.gov/boarddocs/caletters/2009/0902/caltr0902.htm

Revised Investment Policy Template

Investment Policy Template

The update to this product is in response to FDIC's FIL-20-2009 entitled "Risk Management of Investment in Structured Credit Products." The guidance reiterates and clarifies existing supervisory guidance on the purchase and holding of complex structured credit products. It focuses on the various supervisory concerns related to these securities: pre-purchase analysis, suitability determination, risk limits, credit ratings, valuation, ongoing due diligence, adverse classification, and capital treatment.

http://www.fdic.gov/news/news/financial/2009/fil09020.html

Revised Regulation D Policy Template

Regulation D Policy Template

The update to this product is in response to the Federal Reserve Press Release dated May 20, 2009 that announced the approval of final amendments to liberalize the types of transfers consumers can make from savings deposits and to make it easier for community banks that use correspondent banks to receive interest on excess balances held at Federal Reserve Banks.

NOTE: This product was completely rewritten and has been converted into a regulatory specific version at the request of various clients who desired reserve requirement guidance in addition to sample account monitoring procedures.

http://www.federalreserve.gov/newsevents/press/monetary/20090520b.htm

Revised Regulation Z Policy Template

Regulation Z Policy Template

The update to this product is in response to the Federal Reserve Press Release dated May 8, 2009 that announced final rules that revise the disclosure requirements for mortgage loans under Regulation Z (Truth in Lending). The revision implements the Mortgage Disclosure Improvement Act (MDIA), which was enacted in July 2008 as an amendment to the Truth in Lending Act (TILA). Under the MDIA, creditors must comply with the new provisions on July 30, 2009. The regulations apply to dwelling secured consumer loans for which a creditor receives an application on or after July 30, 2009.

http://www.federalreserve.gov/newsevents/press/bcreg/20090508a.htm

What's New, Revised and Deleted

Please visit the following pages of our website to review detailed subject matter regarding new, revised and deleted topics for this product:

Asset, Liability and Liquidity Management Policy Template Update Details

Bank Secrecy Act Policy Template Update Details

Consumer Loan Policy Template Update Details

Investment Policy Template Update Details

Regulation D Policy Template Update Details

Regulation Z Policy Template Update Details

Servicemembers Civil Relief Act Policy Template Update Details

Ordering Information

Click here for pricing information and ordering instructions regarding these revised products.

If you have ordered any of these products after 05/22/09 you are eligible to receive that updated product at no charge.

NOTE: Refer to our Place an Order page for important information regarding payment terms and our return policy. Orders placed for Product Updates are only available directly through Bankpolicies.com.

Find Out What's New or Revised with our Product Update Program

Our Product Update Program allows existing clients to receive e-mail notifications from us the same day we issue a new or revised product. We encourage you to subscribe today for this free and convenient service.