FBLG Banking Letter - December 2018 Edition

Enhancing BSA Policies to Address Marijuana Related Businesses

Fran V. Sponsler, CRCM, CAMS

Currently, 33 states and the District of Columbia have passed laws legalizing marijuana in some form (i.e. medical, recreational or both).  Therefore, it stands to reason that the likelihood of your financial institution offering banking services to an entity or an individual closely related to the marijuana industry (including hemp) is highly probable. 

Whether your financial institution knowingly or unknowingly offers banking services to marijuana/hemp related businesses and/or individuals, your BSA policy may not adequately reflect your financial institution’s intentions.  Depending on your decision to offer banking services, how specific and detailed are those intentions outlined within the program?

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2018 Financial Industry Breach Analysis

Alyssa L. Reeves MIS, CISSP, CISA, CEH

If you have worked with me in the past, you have probably heard my soap box speeches about social engineering and the difference training can make.  In fact, you have probably heard it more than once and politely continued to smile and nod until I finished, then quickly retreated to your desk so you don’t have to hear it again. 

I am happy to report that many of our clients have increased their social engineering training efforts— many are now conducting internal phishing campaigns.  Yet, this is still the most common attack reported to me by clients.  So, I decided to compare the incidents reported to me by our financial institutions against the national statistics. 

I analyzed Verizon’s 2018 Data Breach Investigations Report (the Report), comparing only the Financial Sector to information I have received from our clients and guess what-- there will still be no reprieve from my preaching about social engineering; but there will be one change.  Employees not reporting a phishing email, can be just as detrimental as clicking on the link.  Another take away is that the majority (58%) of victims of security incidents or breaches are categorized as small businesses, meaning community banks will continue to be a target.

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New 2019 Rules for Mileage Expenses

Mark J. Corey CPA, JD

In Notice 2019-02, the IRS detailed the mileage rates for 2019. The optional standard mileage rates are used to calculate the deductible costs of operating an automobile for business, charitable, medical or moving purposes. Starting January 1, 2019, the rates for the use of a car (also vans, pickups or panel trucks) will be:

  • 58 cents/mile driven for business use,
    • Up 3.5 cents from 2018
  • 20 cents/mile driven for medical or moving purposes
    • Up two cents from 2018;
  • 14 cents/mile driven in service of charitable organizations.
    • No change from 2018

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Capital Simplification Rules for Qualifying Institutions

Andrew A. Marshall, CPA

In late November, the Federal Deposit Insurance Corporation (FDIC) issued FIL-77-2018 which discusses a notice of proposed rulemaking related to optional capital simplification rules for qualifying institutions.  With certain exceptions, the rules would be effective for financial institutions with $10 billion or less in total assets.  Highlights taken directly from FIL-77-2018 are below:

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