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FinCEN Provides Relief to CDD Obligations for Existing Customers

April 5, 2018

Authors

Barry Hester

FinCEN Provides Relief to CDD Obligations for Existing Customers

April 5, 2018

by: Barry Hester

The Financial Crimes Enforcement Network (FinCEN) published long-awaited additional Frequently Asked Questions on April 3, 2018 (the “Guidance”) relating to its Customer Due Diligence (CDD) Rule, which FinCEN promulgated pursuant to the Bank Secrecy Act (the “CDD Rule”).  This comes at a time when most covered institutions are in the final stages of implementing plans to comply with the CDD Rule by its May 11, 2018 compliance applicability date.  FinCEN previously published technical amendments to the Rule on September 29, 2017

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Don’t Forget to Consider Deposits in an Acquisition

February 17, 2015

Authors

Michael Shumaker

Don’t Forget to Consider Deposits in an Acquisition

February 17, 2015

by: Michael Shumaker

With many U.S. markets experiencing slow loan growth, some boards of directors looking to increase the size of their institutions have turned to acquisitions to capture greater scale and efficiencies. While asset growth is important, directors should also consider the deposits acquired as part of a merger. Many banks have found that a careful evaluation of the deposits of the selling bank can spot unexpected issues and also drive earnings for the combined institution. The issues and opportunities raised by the liability side of the balance sheet have implications for both buyers and sellers going forward, particularly as

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