Am I behind the times on this one? Is everyone writing a new policy for this new law?

I don't have a policy, but I did write new procedures and required an online training course offered by our training vendor.

Our bank is located in 3 states (including Texas). We're not examined by the Texas State Banking Dept as we are headquartered in another state. Will this state law be reviewed by our federal examiners????

Federal examiners do not examine for State law.

We wrote policies and procedure and did training for our staff.

While your federal examiners won't look at state laws (or at least not without a reason) the new elder protection law requires the bank have a a policy and procedure to comply. You can't just snub the law. Also, employees are required to report suspected financial exploitation to the bank, and the bank is required to assess the case and has a time frame for reporting this to the state.

The bank may enjoy the hold capability it has under this law and has to be aware of the hold times the state or law enforcement may require. Without the above, how will you get this done? Then there are potential SAR requirements as well. Plus, this was all effective Sep 1, 2017.

Okay, federal examiners are not going to ask about the policy. State examiners might.

However, if somebody snookers my maiden Aunt Jane out of her life savings I'm going to cite your lack of a policy required by law as negligence on its face. Put it in place because 1) it's the right thing to do or 2) because failing to do so is an absolute gift to those who would sue you. Either way, put it in place and make it plain to your employees you mean it.

I wouldn't be surprised if state examiners don't ask about it either, but, as Ken said, not addressing it (with policy, procedure, and training) could be a gift to plaintiffs lawyers and a disservice to your vulnerable adult customers.

Remember, in Texas, it is a Class-A misdemeanor to fail to report abuse, neglect or exploitation of the elderly and disabled.