By Donya Parrish, MCU VP-Risk Management
Credit union staff across Montana completed a two-week email training on the Bank Secrecy Act last week. One of the new sections added this year was on the topic of marijuana banking. As board members, it is critical to understand that even if your credit union chooses not to serve the dispensaries, issues arise daily within credit unions on marijuana-related businesses (MRBs). Education is a critical step to ensure that your credit union’s risk level is not unintentionally impacted.
Some of the discussions I’ve had with credit union staff recently on the topic of marijuana banking have dealt with finding an account serving the industry is already open, owners or employees using their personal accounts for business purposes (when they were unable to open an account for the business), or requests for loans from employees of the industry.
It is strongly recommended that your credit union have a board-approved policy on whether or not you are choosing to serve the marijuana industry, including related businesses. If you do not serve MRBs, the policy should include detail on how your credit union will respond if you are approached about accounts or loans, as well as steps that will be taken if you find you already have accounts open that you suspect serve the industry.
If you do choose to serve MRBs, the policy should lay out the steps staff will take for filing the necessary reports (SARs) and collecting and tracking needed information. To appropriately serve MRBs, the credit union may need to dedicate resources, including additional staff, so be prepared to ask questions if you get to this discussion.
Read more about marijuana banking in our recent lesson and make sure you know where your credit union stands, so staff and management are prepared to respond appropriately.