Financial Services General
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Including Digital in Your Budget Process- Part 1 of 2
Just as the timeless holiday song says, it’s the most wonderful time of the year– budget season! Every year at this time, financial institutions are planning their budget for the upcoming year. If you are part of the budget approval team, not only do you need to make sure you work on your “maybe next year” […]
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Regulation E: What Everyone is Talking About
Reg E is a very customer-centric regulation, and that concept does not appear to be changing anytime soon.
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Reporting Loan Modifications with the Implementation of CECL
As a part of the adoption of CECL, institutions are also adopting ASU 2022-02 Financial Instruments – Credit Losses (Topic 326), Troubled Debt Restructurings and Vintage Disclosures. This standard eliminates the concept of a troubled debt restructuring (TDR). As a result of this elimination, it removes the requirement to individually evaluate TDRs for impairment as CECL is already calculating lifetime losses for all loans in the portfolio. Under CECL, you are allowed to individually evaluate loans for allowance levels, but this evaluation is no longer predicated on the prior definition of an impaired loan. However, the standard did not eliminate the requirement for institutions to disclose information about loan modifications where the borrower is experiencing financial difficulty.
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Occupational Fraud in Financial Institutions
This blog was authored by my colleague Kyle Shafer, a manager in our forensic services group. The bank failures have put the spotlight on financial institutions as a result of significant industry regulations. Financial institutions continue to be a target for fraud, but in the modern age of technology and digital advancements prevention and detection […]
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A Trust Company & the Bank Secrecy Act: Is your BSA program good, or good enough?
While all aspects of the Bank Secrecy Act (BSA) rules may not be required for a trust company that are required for depository financial institutions, the oversight obligation and importance is not diminished. Trusts intrinsically have elevated risk based on the transparency of structure, ownership, and purpose. Section 352 of the USA PATRIOT Act requires […]
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Mail Theft and Fraud and SARs…“Oh My!” FinCEN Alert on Mail Theft and SAR Requirements
Have you heard that checks are a dying breed? The industry has been saying that longer than I have been in banking, and that more than half the time I have been alive, yet checks are still being negotiated! According to an article by the Federal Reserve Bank of Atlanta, while checks as a preferred […]
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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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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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Don’t Overlook the R&D Tax Credit for Your Next Fintech Investment
This blog was authored by my colleague Michael De Prima, a principal in our federal tax strategies group. Financial service companies may not seem like typical candidates for research and development (R&D) incentives, but the technology investments these organizations make can present excellent opportunities to capture the R&D tax credit. The federal R&D credit has […]