On October 17, 2019, the Federal Financial Institutions Examination Council (FFIEC) issued the much-anticipated proposed draft Interagency Policy Statement on Allowance for Credit Losses (ACLs). The agencies issued the draft in response to changes in the accounting for credit losses under the Financial Accounting Standards Board (FASB) Accounting Standards Codification (ASC) Topic 326 (most commonly [...]
The current expected credit losses (CECL) journey began with the issuance of an exposure draft in 2010, continued with the issuance of a supplementary document in 2011, and an additional exposure draft in 2012. After much debate and over 3,300 comment letters, the Financial Accounting Standards Board (FASB) released the much-anticipated Accounting Standards Update (ASU) [...]
AML Perspectives Human trafficking is recognized as one of the fastest growing criminal enterprises, and with it comes unique challenges for AML professionals tasked with the detection and related reporting of money laundering red flags. The United Nations Office on Drugs and Crime define human trafficking as “the recruitment, transportation, transfer, [...]
AML Perspectives Much has been made of the “Beneficial Ownership Requirements for Legal Entity Customers,” which went into effect July 11, 2016, with a compliance date May 11, 2018. In fact, on the surface, one could mistakenly ascertain FinCEN’s final rule related solely to beneficial ownership. Furthermore, there are indications that [...]
AML Perspectives The Bank Secrecy Act (or “BSA”) has long been part of the regulatory landscape as a fundamental component of the safety and soundness process. In fact, most professionals who currently work for or with financial institutions do not recall when BSA was not a critical component of the financial institution [...]
AML Perspectives Prevailing FFIEC guidance indicates the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) risk assessment is fundamental to achieving an effective risk-based BSA/AML compliance program. In fact, the FFIEC BSA/AML Examination Manual emphasizes that examiners evaluate the financial institution’s risk assessment as part of the planning and scoping phase of the examination. [...]
AML Perspectives The challenges of BSA/AML compliance continue to evolve for financial institutions as they seek to meet heightened regulatory expectations in areas such as Customer Due Diligence (CDD) or in automating monitoring processes, all while effectively managing the associated cost of ongoing compliance. In the meantime, the Financial Action Task [...]
Although much has changed for financial institutions since the Committee of Sponsoring Organizations (COSO) issued the Enterprise Risk Management (ERM) – Integrated Framework in 2004, much has remained the same. A financial services professional need only check their inbox or scroll through their newsfeed to ascertain that financial institutions, both large and small, are holding [...]
Just as a mountaineer needs a well-trained glacier team to reach the summit of Everest, community banks need effective audit committees to be successful in today’s challenging and changing regulatory and accounting environment. Audit committees provide needed oversight in the areas of risk management and financial reporting. An engaged audit committee is an important attribute [...]
Approximately 2.1 million Americans get married every year, and that number is continuing to rise. As the economy has improved and the banking industry has recovered from the mortgage meltdown, bank marriages (a.k.a., financial institution mergers and acquisitions) are also now in vogue. The banking industry is feeling pressure to tie the knot and “grow the [...]
Since bank examiners pay special attention to the allowance for loan and lease losses (ALLL) as part of a regulatory examination, it doesn’t pay for community banks’ management to stick their heads in the sand. Why? The consequences of a bank’s ALLL being underfunded can be steep and may include: Downgrading the bank's CAMEL rating. [...]
