Monday, March 30, 2020
12:00 – 1:00 pm (Eastern Time)
11:00 – 12:00 pm (Central Time)
10:00 – 11:00 am (Mountain Time)
9:00 – 10:00 am (Pacific 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)
Tiffani has demonstrated experience in providing compliance oversight, training and risk management on the federal and state level. She is specialized in consumer protection laws, mortgage lending regulations, default servicing and third party risk management of certain premiere institutions within the industry. Tiffani has proven experience in developing internal controls of key business processes, their supporting applications, and infrastructure that measure effectiveness and mitigate risk. She is recognized as a highly effective compliance professional in conducting compliance gap analysis and resolving regulatory challenges associated with company-wide business operations. In her role, she has constructed custom end-to-end compliance processes, created compliance audit controls and drafted policies and procedures to support rapidly expanding companies within the mortgage and servicing industry.
1.0 CPE Credits & 1.2 AAP Credits