Each Resource Post

Stay informed with out regularly updated resources. Each post convers a unique aspect of banking or finance to enhance your understanding and enable better financial decisions.

MSB

Why Corporate Due Diligence Files Matter More Than You Think

For many Money Services Businesses (MSBs), corporate due diligence files are completed during onboarding and are not reviewed on a regular basis. Over time, documents expire, registrations lapse, and required updates are overlooked.

The problem is that these files are not simply internal paperwork or a bank requirement. In many states, maintaining accurate and current corporate due diligence documentation is part of an MSB’s broader compliance responsibilities.

When documentation is incomplete or outdated, it can create operational disruptions that directly affect your business.

Why This Matters

One of the most common issues we continue seeing involves outdated or incomplete documentation for businesses whose checks are being cashed.

In many cases, the MSB believes everything is in order until a transaction is reviewed and a problem is identified. By that point, funds may have already been provided to the customer.

When documentation is missing or expired, it can result in:

Delayed or blocked transactions
Compliance concerns
Increased operational risk
Preventable financial losses

These situations are often avoidable with consistent file maintenance and regular internal reviews.

Corporate Due Diligence Is More Than a One-Time Process

Corporate due diligence should be treated as an ongoing operational responsibility, not a one-time onboarding task.

Business information changes regularly. Companies may:

Allow registrations to expire
Change ownership or signers
Update corporate structures
Lose active status with the state
Allow supporting documentation to lapse

Without ongoing reviews, these changes can easily go unnoticed until they create a problem during transaction processing or compliance review.

What Should Be Included in Corporate Due Diligence Files?

Requirements vary depending on the state and type of business, but corporate due diligence files commonly include:

Corporate resolutions
EIN verification from the IRS
Articles of Incorporation or formation documents
Government-issued identification for authorized individuals
Fictitious name registrations, if applicable
Workers’ compensation documentation or exemption records
Business tax receipts or similar local registrations

Many of these documents require periodic renewal or updates.

One of the Biggest Issues We See: Expired Business Registrations

One recurring issue involves businesses failing to maintain active registration status with the Secretary of State.

In states like Florida, corporations are required to file annual reports to remain active. If those filings are missed, the business can become inactive or suspended.

During the due diligence process, Surety Bank reviews business registration status as part of transaction and compliance reviews. If a business is no longer active with the state, transactions may be delayed or unable to proceed until the issue is resolved.

Unfortunately, many MSBs do not discover the problem until after they have already provided funds to the customer.

The Importance of Regular Reviews

One of the best ways to avoid these situations is by implementing consistent internal reviews of your corporate due diligence files.

It is recommended that MSBs review files at least twice a year to ensure documentation remains current and complete.

Even simple tracking methods can make a significant difference. Many businesses successfully use spreadsheets or internal checklists to monitor:

Expiration dates
Annual registration renewals
Tax receipt updates
Insurance documentation
Corporate resolution changes

A small amount of organization upfront can help prevent larger operational and compliance issues later.

Strong Documentation Protects Your Business

Corporate due diligence reviews are not simply administrative tasks. They are part of maintaining a strong compliance program and protecting your business from avoidable risk.

Strong documentation practices help businesses:

Reduce operational disruptions
Improve organization and consistency
Support licensing and compliance obligations
Strengthen internal controls
Prevent unnecessary losses and delays

Most importantly, they help identify problems before they affect day-to-day operations.

Looking Ahead

Maintaining corporate due diligence files may not feel urgent until a transaction is delayed, a registration is found inactive, or documentation cannot be produced when needed.

Consistent reviews, updated records, and proactive tracking procedures help keep operations running smoothly and reduce preventable risk.

In many cases, the businesses with the fewest operational disruptions are simply the ones that stay organized and review their files consistently throughout the year.

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100th Anniversary Stories

A Bank That Knows Your Name: Why John Hamlin Has Trusted Surety Bank for Nearly 20 Years | Customer Profile

For John Hamlin, business has always been about relationships.

As the owner of Hamlin & Associates and several affiliated companies, John has spent decades helping businesses succeed. Throughout his career, he's learned that the strongest partnerships aren't built on transactions alone. They're built on trust, responsiveness, and a genuine commitment to helping people when they need it most.

That's one of the reasons he's been banking with Surety Bank for nearly 20 years.

When John first moved to the Daytona Beach area, Surety Bank was recommended to him by a trusted contact. From his very first interactions with the team, he noticed something different.

"It reminded me more of an old-school bank that cared," John recalls. "I wasn't just an account number. They took the time to learn my name, understand my business, and get to know me."

Over the years, John has worked with other financial institutions, but those experiences only reinforced what makes Surety unique. While larger banks often offered similar products and technology, they couldn't provide the same level of personal attention.

"You can go anywhere and get online banking," he says. "Surety offers that too. The difference is they also offer the personal relationship."

For John, that relationship has meant having direct conversations when questions arise, receiving honest guidance, and knowing that decisions are made by people who understand both his business and his goals.

After nearly two decades as a customer, John says he's never felt the need to call and complain about an employee or a banking experience.

"Everybody in this bank is of service," he explains. "They're accommodating, they're friendly, and they're always willing to help. That's rare."

As Surety Bank celebrates its 100th anniversary, John believes the bank's longevity comes down to something simple: maintaining the personal touch while continuing to evolve.

"You guys can do everything the big banks do," he says. "They can't do everything you do."

For John, that's what community banking should be. Modern conveniences matter, but relationships matter more.

And after nearly 20 years, that's why Surety Bank continues to be his bank of choice.

This is how Surety Bank has always done it and it's how we will always do it!

Watch on YouTube.

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MSB

Independent Reviews Are Not Just a Check-the-Box Requirement

For many Money Services Businesses (MSBs), the independent review is viewed as another annual compliance requirement to complete, submit to the bank, and move on from until next year.

In reality, the independent review is one of the most important tools available to help identify weaknesses in your compliance program before they become larger problems.

A completed review alone is not enough.

What matters is what happens after the review is finished.

Independent testing is one of the pillars of an effective BSA/AML compliance program. Its purpose is not simply to satisfy a requirement. A quality review evaluates the strength of your compliance program, identifies weaknesses or gaps, reviews transaction monitoring procedures, and provides recommendations to improve controls and reduce risk.

A strong independent review gives MSB owners visibility into areas that may need attention before regulators or financial institutions identify them first.

The Most Common Mistake MSBs Make

One of the biggest issues we see is MSBs treating the independent review as a one-time document instead of an operational tool.

In many cases, findings are not addressed, recommendations are delayed, or the same deficiencies continue appearing year after year. This creates a pattern that signals a lack of improvement and a lack of attention to compliance responsibilities.

When the same issues continue repeating, risk increases significantly.

Why Repeated Findings Matter

Repeated deficiencies can eventually lead to increased monitoring requirements, additional compliance costs, regulatory scrutiny, or even fines and penalties. In more serious situations, it can also create risk for the MSB’s banking relationship or licensing status.

In some cases, businesses may be required to undergo additional compliance monitoring by an outside third party until improvements are made.

The goal is not to create an additional burden, but instead to identify and correct issues before they become larger operational or regulatory problems.

Common Areas Where Issues Are Found

Independent reviews frequently identify issues involving:

Late or incomplete CTR filings
Weak transaction monitoring practices
Missing or outdated documentation
Gaps in Customer Due Diligence (CDD) procedures
Inconsistent internal processes or controls

While some of these may seem minor individually, repeated deficiencies over time can create significant compliance concerns if they are not corrected.

Improvement Matters More Than Perfection

No compliance program is perfect. What matters most is identifying issues, addressing them promptly, and demonstrating improvement over time.

An independent review should show progress year after year. If the same findings continue appearing without corrective action, regulators and financial institutions may view that as a lack of commitment to compliance obligations.

Although the independent review report is a bank-required document, MSBs are required to undergo independent testing because the Bank Secrecy Act (BSA) requires every MSB to maintain an effective Anti-Money Laundering (AML) program, and independent testing is one of the core required elements of that program.

Timing and Consistency Matter

While FinCEN requires independent testing to be conducted periodically, Surety Bank’s policy requires independent testing to be completed every 12 months for MSB customers.

Completing reviews consistently and addressing findings in a timely manner helps maintain a stronger and more effective compliance program throughout the year.

Why This Matters

Compliance is not built once a year during an independent testing. It is built through consistent attention to processes, documentation, monitoring, and corrective action throughout the year.

The independent testing is designed to help identify weaknesses before they create larger operational or regulatory problems. Using it properly can help protect your business, your banking relationship, and your long-term success.

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100th Anniversary Stories

When Banking Feels Personal Again: John Simmons & St. Barnabas’ Experience with Surety Bank | Community Profile

For John Simmons, banking with Surety has always been about relationships.

A longtime customer of Surety Bank, John has seen firsthand what it looks like when a financial institution truly shows up for its community. As a husband of 38 years, a father of four daughters, and a Director at St. Barnabas Episcopal School, his perspective is grounded in both family and service.

When the school began to grow, a new challenge emerged. They had run out of space to fit all of the students. Expansion wasn’t just a nice-to-have, it was necessary to continue serving students and families well. Like many organizations in that position, they explored their options carefully.

Then came a call that changed everything.

The president of Surety Bank reached out directly, bringing together key stakeholders in a conversation focused on one thing: how to help. What followed was more than a transaction, it was a collaborative effort. The bank stepped in not just with financial guidance, but with a clear commitment to walk alongside the school’s leadership every step of the way.

That experience left a lasting impression on John.

In his words, Surety Bank was “there 120%,” offering direction, support, and reassurance during a critical moment. But what stood out most was how they got there.

“They treat people as people,” John explains. “They actually answer the phone. They communicate.”

In an era where many businesses prioritize efficiency over connection, that kind of responsiveness feels increasingly rare. Yet for Surety Bank, it’s part of their DNA.

John’s story is a reminder that the best banking relationships aren’t built on numbers alone. They’re built on trust, accessibility, and a genuine investment in the people they serve.

This is how Surety Bank has always done it and it’s how we will always do it!

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MSB

What MSB Owners Need to Know About Oversight and Accountability

Not all risks come from outside your business.

In many cases, the most significant issues we see develop internally through gaps in oversight, compliance, and day-to-day controls.

As we move further into the year, we want to focus on a key principle that helps prevent these issues:

Trust your team, but verify your operations.

A Real-Life Scenario

Consider the following scenario:

An MSB owner invested in the business but was not involved in day-to-day operations. Instead, they trusted a close family member to manage the store and handle compliance responsibilities.

At first, everything appeared to be running smoothly.

Over time, however, several issues developed:

Internal controls were not consistently followed
Compliance requirements were not being properly maintained
Financial activity was not being reviewed regularly by the owner

Eventually, the situation escalated.

The individual managing the business began making unauthorized financial decisions. There were compliance gaps that had gone unnoticed. Required oversight was missing. By the time the issues surfaced, the impact included:

Significant financial loss
Compliance violations
Regulatory action and fines
Operational disruption to the business

The most important takeaway is this:

The responsibility did not fall on the person running the store. It fell on the owner.

Owner Responsibility Does Not Transfer

Even if you assign:

A compliance officer
A store manager
A trusted employee or family member

The responsibility for compliance, licensing, and operations remains with the owner.

Regulators evaluate the licensed entity and the owner behind it, not just the individual performing the work.

A “hands-off” approach can create risk if there is no system in place to verify what is happening inside the business.

Why Internal Issues Are Often Missed

Internal issues are not always obvious.

Unlike external fraud, which is often a single event, internal breakdowns can develop gradually:

Processes are skipped
Reviews are not completed
Reports are not analyzed
Controls become informal instead of structured

Because the business appears to be operating normally, these issues can go unnoticed until they become serious.

The Role of Oversight

Oversight does not mean mistrust. It means protection.

Strong MSB operations include:

Clear internal controls
Active AML and BSA program enforcement
Regular review of financial activity
Independent verification of processes

Owners do not need to manage every transaction, but they do need visibility into how the business is operating.

Practical Ways to Protect Your Business

To reduce risk and strengthen your operation, consider:

Reviewing account activity and reports on a regular basis
Performing periodic spot checks of transactions and documentation
Confirming that compliance procedures are being followed consistently
Ensuring licenses and required documents are current
Evaluating the quality of your independent reviews
Asking questions when something does not look right

Even small, consistent actions can help identify issues early.

Do Not Rely on One Layer of Protection

Independent reviews, compliance officers, and internal staff all play important roles.

However, none of these replace owner oversight.

If any one layer fails, there should be another layer in place to identify and correct the issue.

Final Thought

Trust is important in any business. But in an MSB environment, trust must be supported by structure, process, and verification.

A strong system protects:

Your business
Your customers
Your license
Your long-term success

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Community

Surety Bank Supports DeLand’s Night to Shine

For nearly 100 years, Surety Bank has believed a strong community is built through more than financial services. It's built through people showing up for one another. Since the bank’s early days, Surety has been committed to investing time, support and resources into the places where its customers live and work. That community-first mindset is why Surety was proud to support DeLand’s annual Night to Shine, hosted by Stetson Baptist Church.

History of Night to Shine

Night to Shine is a prom for people with special needs that was created to give honored guests, known as VIPs, a night filled with joy, dignity and belonging. Organizers said this year’s event welcomed about 150 VIPs and was made possible by roughly 400 volunteers who served, cheered and helped make the night unforgettable.

Night to Shine began in 2015 through the Tim Tebow Foundation and has grown into a global initiative hosted by local churches. The foundation says Night to Shine now takes place in all 50 states and in 76 countries, with 979 host churches participating during the 2026 season. In DeLand, the event brought families, volunteers and community partners together around a simple idea: everyone deserves to be celebrated.

A Night Designed to Celebrate VIPs

From the first greeting to the final song, Night to Shine is built around creating a prom experience that feels personal and uplifting. In DeLand, VIPs enjoyed a full evening of fun, including:

Dance floor: Music, lights and plenty of space to celebrate with friends and volunteers.
Karaoke: A chance to grab the mic and hear the room erupt with encouragement.
Caricatures: Artists creating keepsakes that captured the spirit of the night.
Corvette rides: A special highlight for VIPs who wanted a memorable ride and a big moment.
Paparazzi moments: Photos and red-carpet energy that helped VIPs feel like the stars they are.

Each part of the evening reinforced the same message: VIPs are seen, valued and welcomed.

Why Night to Shine Matters in DeLand

People with special needs and their families can too often feel overlooked, simply because many social spaces are not designed with accessibility and inclusion in mind. Night to Shine helps change that by creating an environment where belonging is intentional and celebration is the point. It’s also meaningful for caregivers, who get to watch their loved one experience a community that shows up with kindness and care.

Surety Bank is grateful to support events like Night to Shine because strong communities are built through relationships, service and shared responsibility. The turnout in DeLand reflected that spirit, with volunteers giving their time and local partners helping to make every detail count.

Thank You to the VIPs, Families and Volunteers

To the VIPs who brought the joy, the families who trusted the community with this special night, and the volunteers who made it happen, thank you. Night to Shine is one evening on the calendar, but the impact reaches much further, reminding DeLand what it looks like to celebrate every person with dignity and love.

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MSB, Business Banking

Top Two Reasons for MSBs to Improve Their CTR Filing Process

As a partner to many MSBs throughout the country, Surety Bank has a lot of practical knowledge to share that can help you grow a better business. We take our role seriously and want to provide you with all the resources you need for growth and compliance.

As you know, for any cash transaction above $10,000 in cash, a bank, Money Service Business or any financial institution is required to file a CTR on the individual or entity that is conducting the transaction. The CTR is a form where you will enter the information requested about the person or entity in which you are filing. Then you will upload that information within 15 days. You can find more information about this time frame and answers to many other questions at the link below:

https://www.fincen.gov/frequently-asked-questions-regarding-fincen-currency-transaction-report-ctr

In this article we’ll be covering how you should think about the process of filing a Currency Transaction Report (CTR). This is one of the most routine tasks you may have in your business, but getting it wrong could result in major complications to your business. So, let’s get into the top two reasons you may want to improve your process of filing a CTR.

For example, if you’re a Money Service Business in Miami and you have hundreds of customers that are coming in every day. A lot of those customers could be construction companies that are cashing checks over $10,000 on a daily basis. As an MSB, you would have to file a lot of CTRs. This can get overwhelming as it presents more work for your staff on top of your normal workload for your customers. However, overlooking details can cause a lot of trouble in the future.

Be Thorough.

Where you can get into trouble here is by skipping steps in the process or leaving out any necessary information on each customer. We see MSBs getting into trouble when they don’t take the time to properly fill out and submit the form for each of their customers. Missing information can cause red flags when getting audited.

At Surety Bank, we use software to help us automate a large amount of the work and make sure it is getting done correctly. When a customer comes in deposits $12,000, it would automatically notify us and then would auto fill their information. We would just have to send it in within the given amount of time. Some MSBs are still handling their CTRs manually. If this is you, we would highly recommend getting software to help automate your work and make the reporting more accurate.

File On Time

As an MSB, you have a 15 day window from the time of the transaction to file an accurate CTR on time. It’s gotta be accurate. We’ve seen that some MSBs completely miss the 15 day window and it results negatively on them and their businesses.

A big part of MSBs missing their window or not filing at all for some customer transactions is due to a lack of oversight on specific account activity. For example, let’s say a customer comes in three times in one day and deposits $4,000 each time. That total deposited is $12,000. This requires a CTR on that customer and their transactions. Having software in place would help you catch this while handling this manually will result in many more human errors.

In Summary

If you want to be in business many years from now, our recommendation is to make compliance your competitive advantage. Just like keeping accurate tax records, filing accurate and timely CTRs is the kind of work that will keep you in business for the long haul.

Reach out to our BSA team through our website at mysuretybank.com/msb for more information or connect with directly our CEO by email: rjames@mysuretybank.com.

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MSB, Business Banking

Suspicious Activity Report Best Practices for MSBs

As an MSB, you are probably aware that you have to file a suspicious activity report (SAR) if you detect any kind of facts that point to suspicious financial activity. This is a necessary requirement that can either create a layer of work that detracts from your focus of growth or can become an integral part of your business and fuel growth.

Similar to a Currency Transaction Report (CTR), a SAR reports the information of the customer in question but then gives as much information about the actual suspicious activity found by your team.

Depending on the activity, some customers can fly under the radar if your team isn’t trained to spot subtle actions that add up over time or point to some larger issue. Unlike a CTR, suspicious activity is not always as noticeable. Having a team that is defaulting to a mindset of watching for suspicious activity versus trying to catch things that have already happened is a good start to making this a priority.

Here is a good example of the not so obvious suspicious activity:

Frank Smith comes into your business and asks for 12 money orders in the amount of $1000.00 each. The cash Frank hands over consists of mostly large bills. When you ask him for additional information to complete your CTR he gets defensive and is wondering why you are asking him so many questions. He asks you how much money he can deposit without having to provide additional information. He gets irritated and decides to cancel the transaction and take all his cash back.

https://www.fincen.gov/resources/statutes-regulations/...

This is an example of structuring.

Structuring is the breaking up of transactions for the purpose of evading the Bank Secrecy Act reporting and record keeping requirements and, if appropriate thresholds are met, should be reported as a suspicious transaction under 31 C.F.R. § 103.18.

Why should you make your SAR a priority?

Besides the obvious negative results that will come at some point, making your SAR process a priority puts you in the driver’s seat in your business. You are choosing to stay on top of something that will inevitably blow up if not paid significant attention.

By making this a priority you are also choosing to say no to certain less than desirable customers who might actually be a good source of revenue. As an MSB, at times you can be incentivized to ignore some types of suspicious activity. The trade off between servicing and not reporting customers who bring you revenue or not servicing those customers, is a decision that will keep you in business for many years and allow you to sleep soundly at night. Just remember that one bad customer can put you out of business.

How to properly approach SAR filing:

Use compliance as your competitive advantage. We see MSBs go out of business all the time because they aren’t prioritizing the efforts that make up the fundamentals of their business.

Have a set process for how your team identifies and reports suspicious activity. Build this into your culture. Hiring people who want to help you run a business that’s above board and giving them a solid process, means you don’t have to manage them as closely and can still get the same result.

Reach out to our BSA team through our website at mysuretybank.com/msb for more information or connect with directly our CEO by email: rjames@surety.bank

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Business Expansion

How to Pass Any State Exam

Our ultimate goal with our MSB community is to be a resourceful partner in compliance. We want to see you succeed and see your customers succeed. In this article we’ll cover the very important topic of passing a state exam or an audit. We want to help you understand how to approach it and steps you can take to be successful.

Be Organized

This may seem at first like the simplest approach, but we see MSBs everyday who don’t have their business and paperwork in order. They don’t have foundational systems in which they run their business and it shows in their disorganization. Most of the time not having a formal process that your team can work from begins to disrupt all kinds of other aspects of your business.

Making the choice to get organized is of high value when it comes to passing any state exam or audit. Knowing you can put your hands on any documents that are requested is a good feeling and excellent way to know what is happening at any time in your business. Scrambling last minute to find information usually results in undue stress on you and your team and inevitably creates bigger problems as one event leads to another.

Be Aware of What’s Required

The great part of any state exam or audit is that it is not a mystery. Everything that is required of you is available online. If you want to build a process around a successful exam, take a look at the appropriate resources and prepare accordingly.

Below is the link to the FinCEN MSB Exam manual. This is what FinCEN uses when conducting an exam on a MSB. Studying this document is like getting a copy of the test before you take it.

https://www.fincen.gov/sites/default/files/shared/MSB_Exam_Manual.pdf

There are all the resources you need to comply with the agency who will be examining your business. The bottomline is that you and your team just have to do the front end work of studying them so you can organize your process around them.

Be Respectful

Having helped many MSBs for many years, we’ve seen the potential for some of them to not respect the position or authority of the examiner and the role they play in keeping the industry regulated. As an MSB, it is important for you to do your part in complying with the regulators.

Regulators are just normal people that put on their pants on one leg at a time, just like we do. So treating them with respect and not having a confrontational relationship with them typically leads to them not making you have a bad day. This is very similar to your interaction with a police officer. When you get pulled over, it’s better to just cooperate with their requests (license, registration etc) rather than being disrespectful.

In summary, our best advice is to do the right thing every day. Then it’s not going to feel like you’ve got two years worth of weight on your shoulders trying to get ready for an exam.

If you would like more information on this topic or any topic that is related to running a successfully compliant business, reach out to our BSA team at www.mysuretybank.com/msb.

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MSB

Why Corporate Due Diligence Files Matter More Than You Think

When documentation is incomplete or outdated, it can create operational disruptions that directly affect your business.

Why This Matters

One of the most common issues we continue seeing involves outdated or incomplete documentation for businesses whose checks are being cashed.

In many cases, the MSB believes everything is in order until a transaction is reviewed and a problem is identified. By that point, funds may have already been provided to the customer.

When documentation is missing or expired, it can result in:

Delayed or blocked transactions
Compliance concerns
Increased operational risk
Preventable financial losses

These situations are often avoidable with consistent file maintenance and regular internal reviews.

Corporate Due Diligence Is More Than a One-Time Process

Corporate due diligence should be treated as an ongoing operational responsibility, not a one-time onboarding task.

Business information changes regularly. Companies may:

Allow registrations to expire
Change ownership or signers
Update corporate structures
Lose active status with the state
Allow supporting documentation to lapse

Without ongoing reviews, these changes can easily go unnoticed until they create a problem during transaction processing or compliance review.

What Should Be Included in Corporate Due Diligence Files?

Requirements vary depending on the state and type of business, but corporate due diligence files commonly include:

Corporate resolutions
EIN verification from the IRS
Articles of Incorporation or formation documents
Government-issued identification for authorized individuals
Fictitious name registrations, if applicable
Workers’ compensation documentation or exemption records
Business tax receipts or similar local registrations

Many of these documents require periodic renewal or updates.

One of the Biggest Issues We See: Expired Business Registrations

One recurring issue involves businesses failing to maintain active registration status with the Secretary of State.

In states like Florida, corporations are required to file annual reports to remain active. If those filings are missed, the business can become inactive or suspended.

Unfortunately, many MSBs do not discover the problem until after they have already provided funds to the customer.

The Importance of Regular Reviews

One of the best ways to avoid these situations is by implementing consistent internal reviews of your corporate due diligence files.

It is recommended that MSBs review files at least twice a year to ensure documentation remains current and complete.

Even simple tracking methods can make a significant difference. Many businesses successfully use spreadsheets or internal checklists to monitor:

Expiration dates
Annual registration renewals
Tax receipt updates
Insurance documentation
Corporate resolution changes

A small amount of organization upfront can help prevent larger operational and compliance issues later.

Strong Documentation Protects Your Business

Corporate due diligence reviews are not simply administrative tasks. They are part of maintaining a strong compliance program and protecting your business from avoidable risk.

Strong documentation practices help businesses:

Reduce operational disruptions
Improve organization and consistency
Support licensing and compliance obligations
Strengthen internal controls
Prevent unnecessary losses and delays