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