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Policy Update: BSA/AML

The only thing constant is…

On January 16, 2015, the OCC revised the safety and soundness section of the Comptroller's Handbook. There were significant changes and new guidance to examiners assessing a bank's litigation exposures, associated risks, and risk management practices.

What does this mean for you?
It's time to update your policy and procedures.

What's changed?
  • Additional guidance identifying risks associated with pending litigation and legal matters.
  • Supervisory expectations for managing that risk.
  • Expanded examination procedures to assess both the quantity of risk and the quality of risk management.
What's your responsibility?
Directly quoting from the newly revised Comptroller's Handbook:

"Bank management should have policies and processes in place to reduce the likelihood of litigation, prevent undue harm to the bank's reputation, control expenses associated with litigation, and mitigate potential liabilities."

We know you're busy and we can help remove this item from your list of "to-do's." We've already done all the heavy lifting and created a NEW Litigation Risk Management Program Policy Template addressing ALL the issues raised in the new guidance. All you need to do is order the new policy and procedures template, customize it to fit your institution, and get on to the next item on your list.
Interest Rate Risk Policy Template
The update to this product is in response to the FDIC's "Supervisory Insights - Winter 2014" publication dated 12/18/14, which provides enhanced and detailed guidance regarding a financial institution's requirement to maintain an effective interest rate risk (IRR) management process through the establishment of board approved policies that measure, monitor, and control IRR. As discussed in this article, a successful governance framework is grounded in an informed and involved board of directors that provides senior management with clear policy guidance, sufficient internal resources, and risk mitigation strategies to guide an institution's IRR position well in advance of market shifts.

Regulation X (RESPA) Policy Template   Order Template
Regulation Z Policy Template   Order Template
The update to these products is in response to the CFPB's release entitled "CFPB Finalizes Minor Changes to Know Before You Owe Mortgage Rules" dated 1/20/15 that address when consumers will receive updated disclosures after locking in an interest rate, and how consumers receive information regarding certain construction loans.

If you have previously purchased the Interest Rate Risk Policy Template, Regulation X (RESPA) Policy Template or the Regulation Z Policy Template please email us for discounted pricing to UPDATE your current policy template.

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