Bank Directors Seminar, Coeur d'Alene, ID, September 15-17, 2019

Appraisals

• CSBS committed to raising awareness of appraisal shortages, particularly in rural areas.

• Current Requirements for Commercial & Residential Transactions

• Commercial threshold increases from $250,000 to $500,000 (April 2018) • Residential threshold increases from $250,000 to $400,000 (currently pending)

• Recent Congressional Efforts on Appraisals

• H.R. 2852 – Homebuyer Assistance Act of 2019 (introduced May 2019) • H.R. 3619 – Appraisal Reform Act of 2019 (introduced July 2019)

• North Dakota Granted Partial Temporary Appraisal Waiver

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Bank Secrecy Act/Anti-Money Laundering Reform

What’s the problem?  The current BSA/AML regulatory framework has not undergone substantial changes since 1970.  The banking industry has expressed that BSA/AML compliance requirements are costly and burdensome to meet and that a review of the BSA/AML regulatory regime is needed.  Recently, a Bank Policy Institute (BPI) study found the following:  Survey participants are employing over 14,000 individuals, investing approximately $2.4 billion and utilizing as many as over 20 different IT systems per institution to assist them with BSA/AML compliance;  In 2017, survey participants reviewed approximately 16 million alerts, filed over 640,000 suspicious activity reports (SARs) and more than 5.2 million currency transaction reports (CTRs) and institutions that record data regarding law enforcement inquiries reports that a median of 4% of SARs and an average of 0.44% of CTRs warranted follow-up inquiries from law enforcement.

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