February, 2023

  • FinCEN Alert on Sanctioned Russian Elites

    In January 2023, the Financial Crimes Enforcement Network (FinCEN) published an alert, FIN-2023-Alert002, regarding potential investments in the United States commercial real estate (CRE) market by “sanctioned Russian elites and their proxies”. This Alert follows a similar Alert issued in March 2022, FIN-2022-Alert001. CRE, as mentioned in the Alert, can have highly complex ownership and […]

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  • Fair Isaac Corporation (FICO) Raises Credit Fees for 2023

    On November 22, 2022, the National Consumer Reporting Agency (NCRA) sent a letter to its members announcing that most mortgage lenders would see price increases from Fair Isaac Corporation (FICO) in 2023.  Subsequently, FICO released a statement confirming that prior to September 1, 2022, it had informed the three credit reporting agencies (Equifax, Experian, and TransUnion) that it had adopted a new tier-based royalty structure for credit fees.  

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  • CECL – Post Adoption Considerations

    Over the last ten years, financial institutions have discussed and debated the Current Expected Credit Loss (CECL) accounting standard. Many of the larger financial institutions adopted the standard in 2020 with the majority of smaller, community financial institutions adopting on January 1, 2023. With adoption behind us, here are some items to consider during 2023 to position your financial institution for success in your next regulatory exam or external audit.

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  • As Rates Continue to Increase, So Does Refinance Risk

    When with a group of senior lenders and chief credit officers recently, the question was asked – what keeps you up at night? The answer: refinance risk. Simply put, refinance risk is the risk that a borrower will not be able to refinance their existing loan at favorable terms when it becomes due which could negatively impact their ability to repay the debt.

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  • Financial Services Impacted by New R&D Capitalization Requirements

    This blog was authored by my colleague Sean Croteau, a director in our federal tax strategies group. There are new rules requiring the capitalization of Section 174 costs that apply across many industries, including financial services. Banks, insurance companies, and other players in the financial services space often spend significant resources on research and development […]

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