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Exective Order to Reschedule Marijuana

02/02/2026
Now that the President has issued an Executive Order to reschedule marijuana, what actually changes for banks?

Timing of Next CRA Exam After Receiving Satisfactory Rating

01/05/2026
We received a “Satisfactory” CRA rating in November 2023 and have $3.4 billion in total assets. Under the FDIC’s updated examination guidance, when should we expect our next CRA exam?

CTR Filing to include ATM Transaction

11/04/2025
We have a customer who withdrew $15,000 from their account at a branch, but then another $500 from that same account via an out-of-network (foreign) ATM on the same business day. How should we file the CTR – and should we include the ATM transaction

Form W-9 and New Customers

10/06/2025
Does the bank need to obtain a form W-9 from each of its new customers?

Consumer Complaint Record Retention

09/22/2025
How long should banks keep records of consumer complaints? Our policy says two years or since the last exam, but our state law allows up to seven years. Given the risk, should we extend the retention period?

Onboarding New Customers and Politically Exposed Persons Screening

09/16/2025
When onboarding new customers, is the bank required to check/screen whether they qualify as Politically Exposed Persons (“PEPs”)?

Guarantor to a Loan

09/04/2025
Would our bank be required to obtain a Certificate of Beneficial Ownership on a guarantor to a loan?