Deputy Seminar, Denver, CO
Risks: Commercial Real Estate
• Increasing number of banks that exceed 2006 CRE Guidance levels
• CRE Workprogram (state/FDIC developed and released in 2017) – 2017 Examination results
• Development activity concentrated in urban centers
FinCEN’s CDD Final Rule
• Effective Date May 11, 2018 • FinCEN issued FAQs – April 2018 • FFIEC Examination Procedures/Workprogram issued May 2018 – Examiner Webinar – (recording available)
– CDD Examination Workprogram – Beneficial Ownership Workprogram • COMING SOON : FFIEC Infobase Update
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