Below is the full report. Here’s the introduction
Short-term declines in the number of depository institutions actively providing banking services to marijuana-related businesses (MRBs) may be explained by filers exceeding the 90 day follow-on Suspicious Activity Report (SAR) filing requirement.
Several filers take 180 days or more to file a continuing activity report. After 90 days, a depository institution is no longer counted as providing banking services until a new guidance-related SAR is received.
The number of depository institutions (DIs) banking marijuana-related businesses (MRBs) continues to show a slight decline, which started at the end of the 1st Quarter FY2020 (December), and coincided with the release of guidance by FinCEN and financial regulators on providing financial services to customers engaged in hemp-related business activities.
The COVID-19 pandemic may be adding to this apparent decline for two reasons.
• Some MRBs have likely been closed during this time period, due to government imposed quarantine restrictions.
• Although the 90-day window for filing continuing activity SARs is still in effect, reduced staffing at DIs may have caused additional delays in filing SARs.508_295174_MJ Banking Update 3rd QTR FY2020_Public_508 compliant