The quarterly newsletter for the Chicago Region of FDIC’s Division of Depositor and Consumer Protection published on March 31, 2019 contain a good reminder of a subtle item that is missed by some lenders. The subtle item is contents coverage. You generally don’t take contents as collateral, or do you? Section 329.3(a) of the FDIC’s flood insurance regulation states, in part, that a bank shall not make, increase, extend, or renew any designated loan unless […]
Category: FDIC
AGENCIES PUBLISH ADDITIONAL CECL FAQS
The OCC, FRB, FDIC, and NCUA have published additional frequently asked questions (FAQs) to assist financial institutions and examiners with the new accounting standard, Accounting Standards Update (ASU) 2016-13, Topic 326, “Financial Instruments–Credit Losses” (ASU 2016-13), issued by the Financial Accounting Standards Board (FASB) on June 16, 2016. There are nine additional questions, updated responses to four existing questions, and a new appendix with links to relevant resources that are available to banks to assist […]
REGULATORS OFFER CECL WEBINAR
FDIC FIL-17-2019 announced the federal financial institution regulatory agencies will host an interagency webinar focusing on the application of the Weighted-Average Remaining Maturity (WARM) method for estimating allowances for current expected credit losses (CECL). The event will be held in conjunction with the Financial Accounting Standards Board, the U.S. Securities and Exchange Commission, and the Conference of State Bank Supervisors. The webinar is scheduled for April 11, 2019, at 2:00 p.m. ET. A copy of FIL-17-2019 is […]
FDIC TECH SERVICE PROVIDER CONTRACT CONCERN
On April 2, 12019 the FDIC published FIL-19-2019, which shares observations about gaps in financial institutions’ contracts with technology service providers that may require financial institutions to take additional steps to manage their own business continuity and incident response. The FIL reminded agency-supervised financial institutions that: Their boards of directors and senior management are responsible for managing risks related to relationships with technology service providers. Effective contracts are an important risk management tool for overseeing technology […]
AGENCIES DELAY CECL EFFECTIVE DATE
The OCC, Federal Reserve and FDIC have published a final rule delaying the effective date of their rule to address changes in credit loss accounting under U.S. generally accepted accounting principles, including banking organizations’ implementation of the current expected credit losses methodology (CECL). The final rule had an effective date of April 1, 2019, and provides that banking organizations may early adopt the final rule prior to that date. The agencies have determined that a delay […]