Bank Secrecy Act (“BSA”) Lookback Review

6 Months Ended

Jun. 30, 2017

Bank Secrecy Act Bsa Lookback Review

Bank Secrecy Act (“BSA”) Lookback Review

(15) Bank Secrecy Act (“BSA”) Lookback Review. Under the terms of the Consent Order, the Bank is required to perform a BSA lookback review. The Bank estimates that the cost of the BSA lookback review will range from $250,000 to $300,000 based on an independent firm’s proposal for services. The proposal and ultimate agreement is subject to FDIC review and approval. Until the approval is received, these BSA services cannot be rendered. Once the BSA lookback review begins, the independent firm has 120 days to complete the work. As of June 30, 2017, the Bank has accrued $180,000 for the proposed services.