Cannabis Banking and Vendor Management - Due diligence, SAFE Banking Act and banking MRB’s
Monday, March 30, 2020
12:00 – 1:00 pm (Eastern Time)
The 2018 Farm Bill removed hemp from the Controlled Substances Act and authorized its treatment as an industrial crop. On December 3, 2019, the four federal bank regulatory agencies issued a joint statement clarifying the legal status of hemp growth and production and the relevant requirements under the Bank Secrecy Act (BSA) for banks providing services to hemp-related businesses. It is well known that more and more states are legalizing medical and recreational marijuana, causing federal regulators to face the realization that the cannabis genie will not be put back into the bottle. Because of this ongoing trend, financial institutions are posturing themselves to determine the best way to bank MRB’s and take on the regulatory risks associated with this decision.
One manner in which Banks are mitigating risks is the utilization of technology vendors who are dedicated to cannabis bank compliance. Many demands of banking cannabis businesses fall outside the scope of traditional banking systems, creating considerable administrative work and potential risks due to human error. Therefore, eliminating manual processes that could be error prone, inefficient or costly is the benefit banks hope to attain by using technology vendors and solutions to confirm compliance. However, history has proven that leveraging the services of vendors often creates its own set of risks.
This cannabis compliance training will discuss the impacts of cannabis legalization, the feasibility of banking MRBs in the current legislative environment and the importance of Vendor Management oversight of cannabis solution providers.
Specific Areas Covered:
- Introduction – SAFE Banking Act and the evolving legal and regulatory landscape of cannabis
- Banking MRB’s under the Federal Reserve System – Defining your risk appetite to bank MRB’s and establishing thresholds
- Vendor Management in the world of cannabis – Performing sufficient vendor due diligence and oversight
- Legislative Outlook: A look ahead
Attendees Will Leave Knowing:
- Understanding the implications and possibilities of cannabis banking under the SAFE Act
- Strategies to confirm that your marijuana banking activities comport with risk tolerance and risk management capabilities
- Vendor oversight considerations and best practices
- Aligning FinCEN due diligence expectations with vendor management oversight
- A look ahead: Trends that signal clarity and legal certainty are on the horizon for safe harbor of cannabis banking
Joint statement of Board of Governors of the Federal Reserve System (Dec 3, 2019)
President/Founder – RegConcile
Tiffani Davis is President/Founder of RegConcile and the founding partner at the Law Firm of Davis & Sookoo, PLLC, in the Dallas/Fort Worth, Texas area. She spent over seven years as an Attorney Advisor for the Small Business Administration conducting compliance reviews and rendering legal opinions for their federal disaster assistance lending program. For over six years, Tiffani has worked for one of our nation’s premiere providers in the mortgage and default servicing industry. She is a licensed loan originator in the state of Texas and California and also holds the position of Compliance Officer and Senior Customer Service Manager at one of the largest VA mortgage lenders in the U.S. Tiffani is an active member in the professional networking financial industry groups such as USFN, Mortgage Bankers Association and the Society of Corporate Compliance & Ethics. Tiffani graduated from Southern University Law Center in Baton Rouge, LA and received her L.L.M. in International Trade Law from Bond University in Robina, Australia. She is a licensed attorney in the state of Texas.
Attendance verification for CE credits provided upon request.
Webinar Sponsored by BankersHUB
If you are having issues with registering online, please contact CBAO's Education,Training & Special Events Coordinator, Patti Webb, (614) 610-1877.
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