FBLG Banking Letter - January 2020 Edition

FinCEN CTR Update and Joint Agency Statement on Hemp

Fran V. Sponsler, CRCM, CAMS

Two recently released statements/updates impacting BSA and BSA reporting requirements have been released. The first was issued by FinCEN on October 1, 2019, and is specific to multiple roles when conducting a reportable transaction, as referenced in Question #16 in FinCEN’s CTR FAQ.

The second was issued on December 3, 2019, by Federal and State regulating agencies clarifying the requirements for providing financial services to hemp-related businesses.

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The SECURE Act of 2019

Joseph M. Press, CPA, CFE

While many of us might have been thinking that Congress was preoccupied with non-legislative extracurricular activities during the fourth quarter of 2019, they did manage to pass legislation with sweeping impact on retirement savings plans in the form of the SECURE Act of 2019.  How might this impact you?

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BEC On the Rise, Are You Ready?

Alyssa L. Reeves, MIS, CISSP, CISA, CEH

By now, you have all heard of Business Email Compromise (BEC) cyber-attacks. In fact, many of you have probably seen some sort of BEC or email-based impersonation fraud. The sad fact is that data shows this to only be increasing in frequency and is here to stay. Mimecast, an email and data security company, releases quarterly Email Security Risk Assessment (ESRA) Reports, and when reviewing them, the trends are scary. They found a 269% increase in the number of BEC attacks in quarter three of 2019, compared to the second quarter of the year.

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Flood Disaster Protection Act - Refresher - What is a MIRE?

Val J. Vought, CRCM, CAFP, CAMS

What constitutes a MIRE under the Act? The regulation states that a creditor “shall not Make, Increase, Renew or Extend any loan unless the building or mobile home and any personal property securing the loan is covered by flood insurance for the term of the loan.” This definition includes when the force place insurance premium is added to the principal balance of the loan (protective advance). 

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Grading Classifications and Appropriateness for Downgrading vs. Upgrading

Chaz M. Eiguren, MBA

Banks, in general, are in the business of making money through extending credit to their customers to generate income through the interest charged on the loans, as well as the fees associated with providing the loans. One important piece within the process of the bank's loan management is centered around the bank's loan classifications or how the loans are graded. This can have a dramatic impact on the income generated for the bank through their loans. 

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