While most Americans aren’t focusing on their next tax refund just yet, banks that sponsor, support or issue “tax-refund-related products” need to consider the new guidance issued by the Office of the Comptroller of the Currency (OCC) last month. While the guidance applies to all OCC-supervised banks that offer tax-refund-related products, third party service providers that contract with banks to provide such products also should be aware of the guidance as it is sure to be a factor when amending, renewing or entering into new service agreements with banks for the upcoming tax season. The OCC’s Risk Management Guidance outlines the elements that banks should incorporate into their risk management practices when offering tax refund-related products. Some of the key elements banks will need to consider and address include: the responsibilities of the bank’s board of directors, consumer protection standards, third party risk management, monitoring of third party service providers, fraud prevention measures, anti-money laundering compliance, and training and certification requirements for the overall tax refund program. A copy of OCC Bulletin 2015-36 is available here.