New Product & Service Review

New Product & Service Review

NEW PRODUCT & SERVICE REVIEW

COMPLIANCE ISSUE IDENTIFICATION

Product Name:

Implementation Manager:

Desired/Projected Launch Date:

TO-DO’S

Who / Task
  • Review Agreement between Bank and vendor, if any, gain understanding of how the product/program will work
  • Review vendor due diligence materials to ensure all requirements are met
  • Ensure vendor can comply with all federal and state regulatory requirements for the product or service. If there are gaps, identify them and plan to address

  • Review the Risk Assessment, make comments as needed

  • Get any operational/due diligence questions answered

  • Consider regulatory impacts
  • Outline of compliance aspects of program detailed below.

  • Review any new product codesdeveloped for the product as established in Fiserv or other vendor
  • Review test outputs to ensure product works as intended, reg. issues, [below] as relevant, are addressed

  • Review customer & Bank employee materials/fact sheet of how the product/program will work

  • Review anybrochures/advertisements/special information or procedures developed for the customer

  • Develop/Assist in development of procedures for affected staff to follow.
  • Publish to the intranet

  • Ensure a new workflow in Expedite or other systems needed to accommodate this product and its unique paperwork are developed and compliance issues addressed as they arise in the process

Compliance Dept. Signoff

If there are as yet unresolved operational tasks that need to be implemented to address identified and detailed compliance issues, (identified below as a “GAP”), the Product Manager will keep the Compliance Officer informed on progress to address those issues. Signoff indicates that the compliance issues and gaps have been identified. Mitigation & follow up are ongoing post signoff.

Date / Compliance Officer
Date / Chief Risk Officer

MECHANICS - HOW THE PRODUCT/PROGRAM WILL WORK

  • .
  • .
  • .

REGULATORY ISSUES

Describe How Each Rule’s Requirements Will Be Impacted & Addressed By The New Service Or Product. A “GAP” indicates that there is/could be additional steps the Bank must take to address the issue.

REGULATORY APPROVAL

N/A / YES / DESCRIBE IMPACTS OF RULE/BANK’S ACTIONS
Will an application or notice need to be filed with our federal or state regulator(s), and, if so, do we have the necessary information to submit with the application?

BSA – CIP, OFAC - Consider overall BSA risk profile and impact product may have

N/A / YES / GAP? / DESCRIBE IMPACTS OF RULE/BANK’S ACTIONS/GAP

UNFAIR, DECEPTIVE, ABUSIVE ACTS & PRACTICES [UDAAP] – Also complete detailed UDAAP risk assessment

DESCRIBE IMPACTS OF RULE/BANK’S ACTIONS
Are features, risks, and terms of the product explained clearly and conspicuously, or are they buried in a lengthy document full of "legalese" that makes it difficult for the consumer to make a truly informed choice?
IMPACT
Are fees or penalties structured in such a way that unsuspecting, unsophisticated, or vulnerable consumers could experience financial difficulties from which it would be difficult to extricate themselves?
IMPACT
Are there financial incentives for bank employees to offer this product over other products that may also be suitable for the consumer?
IMPACT
Is this a product or service we would recommend to our families?
IMPACT
??
IMPACT

DEPOSIT RULES

Rule / Covered or NA? / GAP? / DESCRIBE IMPACTS OF RULE/BANK’S ACTIONS/GAP
REG CC/EXPEDITED FUNDS AVAILABILITY ACT
REG E/ELECTRONIC FUNDS TRANSFERS (OD)
REG DD/TRUTH IN SAVINGS
REG D/RESERVE REQUIREMENTS
REG J/CHECK COLLECTIONS
REG GG/ PROHIBITION ON FUNDING UNLAWFUL INTERNET GAMBLING

LENDING RULES

Rule / Covered or NA? / GAP? / DESCRIBE IMPACTS OF RULE/BANK’S ACTIONS/GAP
REG Z/TRUTH IN LENDING/CARD Act
REGULATION B/EQUAL CREDIT OPPORTUNITY ACT
REGULATION C/HMDA
FAIR CREDIT REPORTING ACT
COMMUNITY REINVESTMENT ACT
FAIR DEBT COLLECTION PRACTICES ACT
REAL ESTATE SETTLEMENT PROCEDURES ACT
REG O/LOANS TO INSIDERS
SAFE ACT/MORTGAGE LICENSING
REG U/CREDIT BY BANK FOR PURPOSE OF PURCHASING MARGIN STOCK
REG FF/OBTAINING-USING MEDICAL INFORMATION IN CONNECITON WITH CREDIT

OTHER RULES & REQUIREMENTS

Rule / Covered or NA? / GAP? / DESCRIBE IMPACTS OF RULE/BANK’S ACTIONS/GAP
ESIGN/ELECTRONIC SIGNATURES
GLBA & RFPA/RIGHT TO FINANCIAL PRIVACY
RED FLAG ID THEFT
FDIC INSURANCE
DORMANCY
STATE OF MD ESCHEATMENT RULES
GARNISHMENT OF ACCOUNTS CONTAINING FEDERAL BENEFITS PAYMENTS
SCRA/SERVICEMEMBERS CIVIL RELIEF ACT
DEFENSE DEPARTMENT REGULATION LIMITATIONS ON TERMS OF CONSUMER CREDIT

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11/15/18

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