Saturday, August 24, 2019

Flood Coverage – Still a Hot Regulatory Issue

Posted by OnCourse Staff February 20, 2019 2:42pm
Sample Image Photo Credit: Galina Peshkova

Flood certifications, coverage, insurance, and placement – these are common in any financial institution’s compliance vocabulary nowadays. It’s no secret that all regulatory agencies have had “flood” as a hot topic for the past few review cycles. Financial institutions have been reinforcing their knowledge and awareness of the issue. Yet, even with all of the training that banks and credit unions have paid for and had their employees attend, why are financial institutions still receiving flood violations?

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Interagency Statement on Sharing BSA Resources and Challenges

Posted by OnCourse Staff December 7, 2018 7:34pm
Sample Image Photo Credit: semisatch

On October 3, 2018, an Interagency Statement was issued by five agencies/regulatory bodies to provide banks with an option to enter into a collaborative arrangement involving two or more banks to share their available resources in order to ensure compliance with Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”) requirements...

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Sample Image Photo Credit: Stuart Miles

This past weekend, the New Jersey Legislature and Governor Murphy came to an agreement on Corporate Business Tax ("CBT") changes in connection with the State's 2019 fiscal year budget...

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Correspondent Banking: The Challenges of Data Transparency

Posted by OnCourse Staff January 25, 2018 4:27pm
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As institutions continue to face challenging regulatory regimes and examinations, there are certain takeaways that banks, especially domestic branches of foreign banking organizations (“FBOs”), can benefit from, and adapt to, as a result...

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Regulation E and Business Account Errors

Posted by OnCourse Staff November 6, 2017 2:59pm
Sample Image Photo Credit: olegdudko

I was asked this week, how and when does Regulation E apply to business customers if they report a claim? My answer: it doesn’t, but it could...

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Controls over Employee and Officer T&E Expenses

Posted by OnCourse Staff August 16, 2017 11:05am
Sample Image Photo Credit: Galina Peshkova

Over the past year, we have seen the regulators more closely scrutinizing banks’ expenditures as they relate to Officer’s Travel and Entertainment (“T&E”).  Depending upon the nature of the bank’s business, asset size, and officer structure, controls in this area might vary greatly. However, one thing for sure is that we are moving towards the fact that institutions should have an adequate process in place to address their specific risks...

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Is Regulation CC Put on the Back Burner?

Posted by OnCourse Staff August 15, 2017 4:36pm
Sample Image Photo Credit: prykhodov

Regulation CC was enacted in 1987 in order to standardize hold periods on deposits made to banks and to regulate a bank’s use of deposit holds. There have been many changes throughout the years, but one in particular is that all checks are considered local and clear on a much timelier basis than in earlier years. One thing that remains unchanged is Regulation CC applies to both personal customers and commercial customers...

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Training – An Investment and Risk Management Tool

Posted by OnCourse Staff August 15, 2017 1:19pm
Sample Image Photo Credit: Mikko Lemola

Throughout my entire career in the banking industry, I have been a strong – actually make that an obnoxious – advocate for employee education and training. As a C-level executive at several institutions, I have both encouraged and required staff to seek out any and all seminars, conferences, schools and vendor programs...

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Are You Gambling with Your BSA Program?

Posted by OnCourse Staff June 27, 2017 12:16pm
Sample Image Photo Credit: Vitaliy Kytayko

It’s that time of the year again for your BSA/AML compliance audit.  We know how much you enjoy it when your BSA internal auditors show up with smiles as big and long as their request memos and sample sizes – from policies to procedures...

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The Case of Foreign Banks and Heightened Scrutiny

Posted by OnCourse Staff March 24, 2017 2:35pm
Sample Image Photo Credit: Kheng Ho Toh

There is what appears to be a trend happening in the foreign branch banking market that seems all too consistent. That trend is the influx of MRAs, MOUs, and Consent Orders being handed down by the federal regulators for having insufficient BSA/AML and OFAC compliance programs.

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IRS and New Jersey Tax Audits of Banks

Posted by OnCourse Staff March 16, 2017 4:57pm
Sample Image Photo Credit: Val Goretsky

Budget deficits and other fiscal concerns combined with challenging economic conditions continue to place pressure on federal and state governments to generate increased revenue through tax collections...

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State Taxation of Financial Institutions in Today's Environment

Posted by OnCourse Staff February 24, 2017 7:29pm
Sample Image Photo Credit: Megan Shull

Among the most challenging areas of taxation confronting banks today are the state tax ramifications resulting from the institution's business activities. With the prevalence of Internet-based activities, expansion of services offered by banks and extended geographic reach, the evaluation of state tax implications is much more complicated and requires greater analysis.

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Does your 401(k) Plan need an Audit?

Posted by OnCourse Staff January 25, 2017 12:32pm
Sample Image Photo Credit: adiruch

The July 31st reporting deadline for employee benefit plan Form 5500s will be upon us in the blink of an eye; it’s important for banks to be familiar with the 401(k) audit compliance rules before it’s time to file.

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De-Risking of Foreign Correspondent Banks

Posted by OnCourse Staff January 24, 2017 5:36pm
Sample Image Photo Credit: Michael Borgers

On October 5, 2016, the Office of Comptroller of Currency (“OCC”) issued guidance relative to foreign financial institutions de-risking policies with respect to maintaining foreign correspondent banking relationships.

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Same Day ACH Credits – Phase One

Posted by OnCourse Staff October 24, 2016 2:07pm
Sample Image Photo Credit: Daniil Peshkov

In today’s environment, we want everything faster, especially when it comes to our finances. National Automated Clearing House Association (“NACHA”) has adopted a new rule that will enable same-day processing for ACH credits received by the Receiving Depository Financial Institution (“RDFI”).

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Sample Image Photo Credit: Scandinavian Stock

As the saying goes, the chickens have finally come to roost. FinCEN and the banking authorities have issued a final ruling on beneficial ownership with respect to Customer Due Diligence, now requiring financial institutions to identify beneficial owners of covered businesses as part of the account opening process.

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Keep an Eye On Your Chip!

Posted by OnCourse Staff August 1, 2016 5:38pm
Sample Image Photo Credit: alicephoto

By now, a lot of credit card and debit card companies in the U.S. have begun to issue cards with the new “chip” technology. Here’s a little background on the chip card technology and its unfolding in the U.S...

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Is the IRS Status of your Defined Benefit plan in Jeopardy?

Posted by OnCourse Staff July 8, 2016 2:17pm
Sample Image Photo Credit: lightwise

Electronic certification (“e-certification”) for loans and hardship withdrawals, without the retention of appropriate supporting documentation, is considered a QUALIFICATION FAILURE.

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Sample Image Photo Credit: David Carillet

We’ve all come to the realization that the legalization of marijuana in the U.S. is something that is becoming more and more prevalent. As state legislatures and lawmakers have since softened their policies on marijuana usage (medicinal or recreational) and begun to see the monetary benefits of legalizing such at the state level, there still presents a heightened risk of money laundering in the banking industry.

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Is your Institution Monitoring Working Capital Lines of Credit?

Posted by OnCourse Staff December 14, 2015 12:05pm
Sample Image Photo Credit: fotoall

Working Capital Lines of Credit (“LOC”) are one of many forms of Commercial and Industrial (“C&I”) lending. These LOCs are common in commercial banking and are relatively riskier when compared to Commercial Real Estate and/or Residential loans. They are generally secured by an UCC-1 lien on business assets or are unsecured and solely rely on the borrower’s strong cash flow. Due to the elevated risk, banks should monitor these loans closely and have proper processes and procedures in place.

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Financial Reporting and Regulatory Update on the Horizon

Posted by OnCourse Staff November 9, 2015 11:41am
Sample Image Photo Credit: Murali Nath

Taking a look at what pension-related legislative initiatives are winding their way through the halls of Congress, it is apparent that we have a very thin legislative agenda.

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BSA/AML Training: Is your program effective?

Posted by OnCourse Staff August 28, 2015 12:55pm
Sample Image Photo Credit: Maksim Kabakou

Ongoing BSA/AML training is one of the main pillars of a safe and sound BSA/AML compliance program. Knowledgeable staff, especially in areas with heightened exposure to money laundering (i.e., Tellers, CSRs, Branch Managers) can have a significantly positive impact on the Bank’s BSA/AML compliance program.

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Planning in a Consolidating Banking Industry

Posted by OnCourse Staff August 10, 2015 6:00pm
Sample Image Photo Credit: Robert Churchill

It’s no secret that the number of community banking institutions is decreasing and that this trend will continue into the future. Included in their strategic planning and Board discussions, management and directors need to ask a critical question...

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Sample Image Photo Credit: http://www.business2community.com

Over the last year there has been much discussion regarding the changes in regulatory capital measurement and reporting rules for Community Banks.

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Anti-Money Laundering – The Age of Technology

Posted by OnCourse Staff March 16, 2015 11:39am
Sample Image Photo Credit: centralbanking.com

With the ever increasing regulatory scrutiny facing the banking industry, community banks, small and large, have looked upon technology as a resolution to its problems. In the past, many banks were able to manage money laundering risks...

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Top Compliance Topics Discussed at the NJ Bankers Compliance University

Posted by OnCourse Staff February 13, 2015 11:46am
Sample Image Photo Credit: nationalmortgagenews.com/

So I attended the NJ Bankers Compliance University in June 2014 and wanted to share some of the information that I came away with to try to assist community banks in knowing where the regulators are going to focus their attention. Please note that these are in no particular...

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Some tips and tricks for dealing with Regulatory Examinations

Posted by OnCourse Staff February 13, 2015 11:29am
Sample Image Photo Credit: blog.regulatorycompliance.com

  • Designate a central point of contact to coordinate examination matters and deliver requested information – the “Examination Manager.”
  • The examination manager is the chief liaison with the Examiner in Charge (“EIC”) and the examination team, and will resolve any examination issues while examiners are on-site.
....

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Updated Regulation E Booklet from the OCC!

Posted by OnCourse Staff February 13, 2015 11:15am
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On August 28, 2014, the Office of the Comptroller of the Currency issued the “Electronic Fund Transfer Act” booklet of the Comptroller's Handbook. This revised booklet replaces a similarly titled booklet issued in October 2011. This updated booklet provides updated guidance to examiners and bankers relevant to recent changes made to Regulation E (12 CFR 1005) regarding remittance transfers. These rules are promulgated by the CFPB and stem from the 2010 Dodd-Frank financial reform law.

Community Banks must be aware that the...

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Is Flood Disaster Still on the Heat Map?

Posted by OnCourse Staff February 13, 2015 11:07am
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You bet it is!!!! With all of the training banks have paid for and had their employees attend, why are banks still getting flood violations?

There are many ways to violate the flood hazard requirements: you could fail to timely or properly complete the Standard Flood Hazard Determination Form on covered loans, not give the borrower the notice of flood hazards within the right timeframe...

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Have You Implemented Your Plan yet?

Posted by OnCourse Staff February 13, 2015 11:03am
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Not only do financial institutions have to be in compliance with the new mortgage rules implemented as a result of the Dodd Frank Act, but they have to have a PLAN in place FIRST, to implement the changes.

During initial examinations for compliance with the new regulations, FDIC examiners will expect institutions to be familiar with the mortgage rules' requirements and have a plan for implementing the requirements. The FDIC notes that implementation plans should contain .

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FDIC Consumer Newsletter

Posted by OnCourse Staff February 13, 2015 10:58am
Sample Image Photo Credit: FDIC

The winter issue of the FDIC Consumer News features tips on choosing and using credit cards. Other topics include: ways to protect personal information, money and banking tips for the tax season, testing one's deposit insurance IQ, and preparing for rising home equity line payments.

Credit cards are an important part of many consumers' financial lives, but it helps to understand how to make the most of these products and avoid...

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More Flood Insurance Changes...

Posted by OnCourse Staff February 12, 2015 9:36am
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On July 6, 2012, the Biggert-Waters Flood Insurance Reform Act of 2012 (“B-W Act”) became law. The B-W Act made several substantial changes to the flood insurance rules, many of which affected lenders. While most provisions were effective only after implementing regulations are written, two major provisions of the B-W Act, one regarding the force placement...

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Following on the heels of the Supreme Court’s June 26, 2013 decision in United States v. Windsor, Director Richard Cordray of the CFPB issued a memorandum setting forth guidance on equal treatment for legally married same-sex couples.

He stated, “It is the Bureau’s policy, to the extent...

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The Bureau of Consumer Financial Protection (“Bureau”) issued a final rule amending the regulatory text and official interpretations for Regulation Z, which implements the Truth in Lending Act (“TILA”). The Bureau is required to calculate annually the dollar amounts for several provisions in Regulation Z; this final rule reviews the dollar amounts for provisions implementing amendments to TILA under the Credit Card Accountability Responsibility and Disclosure Act of 2009 (“CARD Act”), the Home Ownership...

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FFIEC Releases Revised BSA/AML Examination Manual: So what’s new?

Posted by OnCourse Staff February 5, 2015 10:51am
Sample Image Photo Credit: altankoman

On December 2, 2014, the Federal Financial Institutions Examination Council (“FFIEC”) released the revised Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. The 2014 BSA/AML examination manual incorporates several regulatory changes and provides further clarity on regulatory expectations since the last examination manual was released in 2010.

So what are some of the new changes?

There are several areas within the new examination manual that have incorporated current regulatory requirements....

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OFAC Consolidates Non-SDN Listings

Posted by OnCourse Staff February 5, 2015 10:43am
Sample Image Photo Credit: altankoman

In the past, banks were burdened with having to monitor updates to the SDN (Specially Designated Nationals) as well as the non-SDN sanctioned listings. Many have asked “Why are there so many different listings? Why not have a consolidated set of listings in a single file?” The Office of Foreign Assets Control has now made it easier for banks to comply with sanction screening requirements by distributing a consolidated listing...

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Coping with HOPA

Posted by OnCourse Staff January 19, 2015 4:57pm
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On February 25, 2014, the FDIC released its revised interagency consumer compliance exam procedures for the mortgage rules that became effective with the Dodd-Frank Act. The focus of the issuance of the procedures is part of the FDIC's efforts to inform affected banks about bank regulatory developments in hopes of creating a better dialogue between the FDIC and the institutions it...

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Coping with the CFPB’s Ability-to-Repay Rule

Posted by OnCourse Staff January 19, 2015 4:43pm
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On January 10, 2013, the Consumer Financial Protection Bureau (“CFPB”) released its final Ability-to-Repay (“ATR”) and Qualified Mortgage Rule, effective January 10, 2014. Our Subject Matter Experts in our Regulatory...

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ABA Survey on Impact of Dodd Frank Compliance

Posted by OnCourse Staff January 19, 2015 4:34pm
Sample Image Photo Credit: ABA

In case you were wondering about the impact of the implementation of compliance with the Dodd Frank Act, check out this survey taken by the ABA last summer. I have wondered what the effects would be and this survey has confirmed my earlier

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ABA Mortgage Origination Deskbook

Posted by OnCourse Staff January 19, 2015 4:26pm
Sample Image Photo Credit: ABA

ABA and law firm BuckleySandler released “The New CFPB Mortgage Origination Rules Deskbook,” a free and comprehensive reference guide to help bankers understand and comply with the CFPB’s rules when originating loans.

The ABA members-only deskbook — available in a printable electronic format — consolidates all available CFPB compliance guidance. In addition to the rule text and official commentary, the deskbook encompasses CFPB interpretive rules...

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Who handles Your Dormant Accounts?

Posted by OnCourse Staff November 26, 2014 2:03pm
Sample Image Photo Credit: hin255

Do your tellers have access to determine which accounts at your Bank have become dormant? Or is your dormant account function housed in your back-office Operations Department? I had a conversation with a colleague of mine the other day that sparked me to write on this topic. They told me that they still had a passbook savings account and that they hadn’t updated their passbook in the branch for several years. This prompted me to...

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Appraisal Disclosure Rule

Posted by OnCourse Staff November 26, 2014 2:01pm
Sample Image Photo Credit: biwizeauto.com

Effective January 8, 2014, the new Rules on providing appraisals and other valuations went live in accordance with the Dodd-Frank amendments to Reg B, commonly referred to as the ECOA Valuations Rule. When something relatively significant like this goes into effect, there can be some confusion as to what exactly is covered under the new criteria, and if any exemptions or waivers exist for commercial/business type ventures. However, the short answer is no. Commercial loan applications are now subject to the same disclosure requirements that...

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Cybercriminals Broaden their Attacks in Social Networks

Posted by OnCourse Staff September 18, 2014 11:15am
Sample Image Photo Credit: StefanG81

Cybercrime attacks in Social Networking platform is listed as one of the Top 10 IT Security Issues for 2014 by SC Magazine for IT Security Professionals. Cybercrime is defined in Wikipedia as any crime that either uses or targets a computer in the accomplishment of a crime. Cybercrime attacks are prevalent in popular social and professional networks such as Facebook, Twitter, YouTube and LinkedIn.

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Sample Image Photo Credit: Ambro

A lending staff’s primary function is to generate revenue for the bank by both generating new borrowers and by cross-selling existing products to existing clients. A credit department’s primary focus is to ensure that all loans are approved in accordance with the Bank’s lending and credit policies and to assess the sufficiency of a borrower’s cash flow to repay the subject loan.

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Appraisal Management Companies in Regulatory Crosshairs

Posted by OnCourse Staff April 9, 2014 2:59pm
Sample Image Photo Credit: Gualberto107

The alphabet soup of regulatory agencies (OCC, FRB, FDIC, CFPB, FHFA and NCUA) have issued a set of rule proposals that would apply basic standards for state registration and supervision of appraisal management companies (AMCs).

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All About the Home Owners Protection Act

Posted by OnCourse Staff April 9, 2014 2:17pm
Sample Image Photo Credit: freedigitalphotos.net

On February 25, 2014, the FDIC has released its revised interagency consumer compliance exam procedures for the mortgage rules that became effective with Dodd-Frank Act. The focus of the issuance of the procedures is part of the FDIC's efforts to inform affected banks about bank regulatory developments in hopes of creating a better dialogue between the FDIC and the institutions it monitors.

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Requesting Current Financial Information

Posted by OnCourse Staff April 8, 2014 5:02pm
Sample Image Photo Credit: FDIC

Loans in general rely heavily on current financial information of the Borrower to determine the repayment capacity of the Borrower. Current Tax Returns, Rent Roll (if applicable), Personal Financial Statements and supplementary documentation are some of the more common forms of financial information used banks.

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Countdown to Windows XP End of Life and Support: Are you still at Risk?

Posted by OnCourse Staff March 24, 2014 4:23pm
Sample Image Photo Credit: sanand

According to Microsoft, support for Windows XP ends on April 8, 2014. This means that starting this date, Microsoft will stop providing technical assistance, hotfixes and security updates to protect Windows XP computers and devices.

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314(b) Distinct Advantages for Financial Institutions

Posted by OnCourse Staff March 5, 2014 11:55am
Sample Image Photo Credit: Keattikorn

There are distinct advantages for financial institutions who participate in information sharing 314(b). It will help protect community banks from financial and reputational risk as well as paint a better picture of the customer whom they are doing business with.

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Where is the Document?

Posted by OnCourse Staff January 24, 2014 5:40pm
Sample Image Photo Credit: stockphoto.net

This is probably the most frequent question we ask bank personnel when the firm is engaged to review loan files. Each Community Bank has its own way of organizing loan files. Based on the type of loan and number of borrowers, these files can be very small, very large, or a combination of everything in between.

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The Credit -- Er, IT Crisis?

Posted by OnCourse Staff January 17, 2014 11:49am
Sample Image Photo Credit: Fred Goldstein

The credit crisis and subsequent recession got me thinking about the potential for a similar “IT crisis” in community banking.

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Building a Better Hen House

Posted by OnCourse Staff January 17, 2014 11:49am
Sample Image Photo Credit: Free Digitial Photos

For the banking industry, IT Security is an ever changing concern that must be addressed with the most recent threats in mind. For many institutions, security is handled by policy based IT audits and annual penetration tests performed by external vendors.

To truly prevent a fox from getting into your “hen house,” so to speak, you must go above and beyond penetration tests and policy based IT audits. Below is a recent conversation I had with “Joe Management” where I discuss one way to go above and beyond – the vulnerability assessment.

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Ready the Ramparts! : IT Security and the Modern Bank

Posted by OnCourse Staff January 17, 2014 11:49am
Sample Image Photo Credit: Tom Curtis

From the Manhattan District Attorney's Office

"Manhattan District Attorney Cyrus R. Vance, Jr., today [September, 30th] announced the indictments of 36 individuals for their participation in several large-scale international identity theft and cybercrime rings that stole more than $860,000 from 34 separate corporate and individual victims in the United States. The defendants, foreign students who were in the United States on Exchange Visitor Visas, are charged with opening bank accounts at JP Morgan Chase Bank and other financial institutions in New York County and elsewhere, for the purpose of receiving fraudulent transfers from identity theft victims’ bank accounts. (District Attorney, 2010)".

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Keeping the Balance: IT Security and the Org Chart

Posted by OnCourse Staff January 17, 2014 11:49am
Sample Image Photo Credit: Felipe Horst

One of the most difficult things for a community bank to do is to balance the efficiency we need from IT - with the security IT requires. Efficiency and security have an inverse relationship to one another. You can have high efficiency or high security, but not both. It’s like an old scale or a children’s seesaw. As security controls of a system are increased, the efficiency gained from the system decreases – and vice versa. For example, I can be really secure by unplugging my Internet connection from the wall, but it’s not very practical and certainly wouldn’t be very efficient.

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Consumerization of Technology and its influence on Information Security

Posted by OnCourse Staff January 17, 2014 11:49am
Sample Image Photo Credit: SimonOk

Unless you’ve been living under a rock for the past few years, you’ve probably heard of a trojan known as Zeus. It is often referred to as the "Man-in-the-Browser" because it begins by infecting the customer, not the institution. It takes advantage of vulnerabilities on a customer’s computer and waits for the customer to connect to an institution’s website. Once the customer connects, the trojan is capable of detecting that the customer is browsing a financial institution’s website and can silently make transactions in the background. It can also alert the attacker in real-time so that the attacker can hijack the customers session and manually perform transactions of his own.

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IT Security: "IT's" About Process

Posted by OnCourse Staff January 17, 2014 11:49am
Sample Image Photo Credit: Rawich

Effective corporate governance is perhaps the single most effective security control in an institution. In community financial institutions, it is usually the responsibility of the audit or supervisory committee to hold management accountable for the decisions they make. That includes holding the information security officer accountable for the security issues identified as part of internal audits and security assessments. An audit committee can have a very positive, or negative impact on organizational security, which will largely be a function of how capable the committee is at managing an area that has quickly evolving threats and risks.

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Wag the Dog

Posted by OnCourse Staff January 17, 2014 11:49am
Sample Image Photo Credit: Gideon Geldenhuys

It is the financial institution’s responsibility to secure the network and the data that resides therein. A common attitude that I see in community financial institutions is that the institutions only feel obligated to implement security insofar as the regulators have issues. In other words, many institutions will balk at the idea of implementing controls, and spending money, until the regulators demand it. That thought process is fundamentally incorrect.

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Detective, Reactive and Preventive: Evolving Your IT Security

Posted by OnCourse Staff January 17, 2014 11:49am
Sample Image Photo Credit: clix

In my The Credit – Er, IT Crisis post I talked about some of the forces influencing security in community banking. One of the forces I mentioned was that the audit process has remained largely the same, while at the same time, the IT environments of modern banks are rapidly evolving. But what does that mean? Given the evolving environment, how does the audit process have to evolve to ensure the information security of a community bank? What does a community bank need to do to complement the audit process?

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Do You Know The Security Features of the New $100 Bill?

Posted by OnCourse Staff December 16, 2013 4:46pm
Sample Image Photo Credit: Stuart Miles

Have you ever went to a Bank, handed the teller a $100 bill, and notice him/her carefully examining it? Have you ever had the employee at the gas station refuse to take your $100 bill? Nowadays, everyone is skeptical about receiving currency from an outside source other than a financial institution due to the circulation of counterfeit money. So, to stay ahead of and to lower counterfeit money....

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Segregation of Duties for Wire Transfer Processing

Posted by OnCourse Staff December 16, 2013 4:33pm
Sample Image Photo Credit: FreeDigitalPhotos.net

Establishing and maintaining effective controls is one of Banking’s major responsibilities. One primary control includes appropriate separation of duties with the daily processing of Wire Transfers. With the increasing number of internal and external Wire Transfer fraud, this process is being scrutinized by Banking Regulators. Segregating duties is one of the most important functions of a substantial internal control system.

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How do you charge Early Withdrawal Fees on Time Deposits?

Posted by OnCourse Staff December 16, 2013 4:25pm
Sample Image Photo Credit: ctoocheck

One thing I have suggested to bankers in a low interest rate environment is to review their early withdrawal penalty on time deposits. Most institutions calculate the early withdrawal penalty as a number of days of interest.

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Do you still offer NOW Accounts?

Posted by OnCourse Staff October 8, 2013 12:54pm
Sample Image Photo Credit: hin255

A demand deposit account is a checking account. Most demand deposit accounts (“DDA”) allows the customer to withdraw money from their account without advance notice, but the term also includes accounts that require six days or less of advance notice.

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Policy Changes Required – Do you Wait until Annual Approval?

Posted by OnCourse Staff September 19, 2013 5:23pm
Sample Image Photo Credit: 4seasons

Let’s say a team of BSA internal auditors come in and audit your Bank. At the conclusion of the audit, an internal audit report is issued to the Bank’s audit committee with a recommendation for changes to the BSA policy. Management indicates in their response to the audit report that they agree with the recommended changes and will update the policy accordingly. Now come the questions..

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Summarizing ACAMS White Paper on EDD and AML Risk Assessments (Industry Survey)

Posted by OnCourse Staff September 19, 2013 4:47pm
Sample Image Photo Credit: fdp.net

The Association of Certified Anti-Money Laundering Specialists recently published a White Paper summarizing an industry survey study of current practices regarding Customer EDD and AML Risk Assessment. The compelling analysis included survey of approximately 500 respondents regarding industry standards for Customer EDD and Bank wide BSA/AML Risk Assessment practices.

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ACAMS to provide Free Webinar

Posted by OnCourse Staff August 23, 2013 11:23am
Sample Image Photo Credit: free digital phts

The Association of Certified Anti-Money Laundering Specialists (“ACAMS”) is an association that provides training and certification, runs conferences and disseminates information on detection and prevention of money laundering. ACAMS was founded in 2001 and has grown immensely since then. ACAMS is now the largest international membership organization dedicated to enhancing the knowledge and expertise of Anti-Money Laundering (“AML”) and financial crime detection and prevention professionals.

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ACBB Changes its Name

Posted by OnCourse Staff August 23, 2013 10:46am
Sample Image Photo Credit: sixninepixels

In the New Jersey Banker’s Bulletin dated August 21, 2013, there is an article in regards to ACBB changing its name from Atlantic “Central” Banker’s Bank to Atlantic “Community” Banker’s Bank.

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Who Do You Give Cash to?

Posted by OnCourse Staff August 14, 2013 3:39pm
Sample Image Photo Credit: kaifreedom

Many historical internal frauds stem from teller theft or Customer Representative personnel theft. Unfortunately branch personnel can become intuitive in figuring out ways to redirect funds from the cash box or from a customer. This is a concern that keeps Senior Management and even Board members often worried.

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ABA Briefing to Help Banks Address Cyber-security Threats

Posted by OnCourse Staff August 14, 2013 3:30pm
Sample Image Photo Credit: scottchan

Computer security (Also known as cyber-security or IT Security) is information security as applied to computers and networks. The field covers all the processes and mechanisms by which computer-based equipment, information and services are protected from unintended or unauthorized access, change or destruction. Computer security also includes protection from unplanned events and natural disasters.

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The OCC Issues Booklet: “A Common Sense Approach to Community Banking”

Posted by OnCourse Staff August 9, 2013 12:34pm
Sample Image Photo Credit: hin255

On June 13, 2013, the OCC issued a booklet titled, “A Common Sense Approach to Community Banking”. The booklet was previously distributed to national banks and federally chartered thrifts, however, is now available on the OCC’s Website.

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Safe Deposit Box Contents are not insured – But They COULD Be!

Posted by OnCourse Staff August 7, 2013 3:29pm
Sample Image Photo Credit: hin255

Safe Deposit Box contents are not insured by most Banks and are not insured by the FDIC. If you have signed a safe deposit box contract with the Bank, you most likely have to read directly on the contract that the contents of your box are not insured.

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Allowance for Loan Loss Tips and Tricks

Posted by OnCourse Staff August 7, 2013 2:14pm
Sample Image Photo Credit: David Castillo

A bank’s Allowance for Loan Loss is a perennial hot button issue amongst both state and federal regulatory agencies. It is, without a doubt, one of the most detailed and high risk audits our firm conducts.

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FDIC Can Review New Products

Posted by OnCourse Staff July 31, 2013 12:09pm
Sample Image Photo Credit: adamr

Last month, I attended an ABA Regulatory Compliance teleconference. Towards the end of the conference, an FDIC representative said was that if a Bank has a new product that they are planning on offering to customers, the Bank can call the FDIC and they will personally send someone from the FDIC out to the Bank to review all aspects of the new product prior to...

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Let’s Talk About Overdrafts!

Posted by OnCourse Staff July 25, 2013 4:57pm
Sample Image Photo Credit: scottchan

An overdraft occurs when money is withdrawn from a bank account and the available balance goes below zero. In this situation, the account is said to be "overdrawn". Overdrafts are a leading compliance concern due to lost revenue, heightened compliance risk, and threats of UDAAP violations.

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Community Banks Slowly Warm Up to Private Student Loans

Posted by OnCourse Staff July 25, 2013 3:58pm
Sample Image Photo Credit: ppdigital

Looking to diversify, a number of smaller banks are considering making more student loans, even as bigger banks head for the exits. The key is to stay disciplined, community bankers say.

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Has your Bank updated the Adverse Action Notice?

Posted by OnCourse Staff July 25, 2013 1:58pm
Sample Image Photo Credit: Stuart Miles

An adverse action notice is given to any potential borrower who applies for credit and is denied. This notice is required to be sent out to the customer within 30 days of the application date, and must include the name, address, and telephone number of the person for further explanation of the specific reasons for denial.

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Sample Image Photo Credit: Stuart Miles

A majority of our banking transactions are now handled electronically. In banking, this can cause an unwanted customer service issue when a customer wants to "stop payment" on an electronic item, especially on a recurring debit.

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CFPB Stands Up Against Poor Debt Collection Practices

Posted by OnCourse Staff July 12, 2013 11:25am
Sample Image Photo Credit: hin255

On July 10, 2013, the CFPB notified all companies under its jurisdiction that they will be held accountable for unlawful conduct in collecting a consumer’s debts and issued Bulletin’s on Debt Collection.

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Don’t Forget the Small Stuff

Posted by OnCourse Staff July 11, 2013 11:12am
Sample Image Photo Credit: Suat Eman

With the current “eye of the regulatory storm” being mostly focused on asset quality, IRR and problem loans, you might be forgetting to check up on “not so blatantly obvious” potential for regulatory scrutiny.

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Double Endorsed Checks: What is the Risk?

Posted by OnCourse Staff July 3, 2013 2:38pm
Sample Image Photo Credit: muresan113

There are risks involved in the deposit of a double (or triple) endorsed check. The biggest risk being forgery. Even if the Bank knows and trusts the endorsement of the bank's depositor (the second endorser), generally they cannot verify the authenticity of the first endorsement. If the first endorsement is a forgery, or unauthorized, the depositary bank will be liable on their warranty that each of the prior endorsements was genuine and authorized, and that warranty extends for between one year and three years under the Uniform Commercial Code.

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Social Media – Will the Regulators Do Spot Checks?

Posted by OnCourse Staff June 25, 2013 12:23pm
Sample Image Photo Credit: ctoocheck

found out today that the Financial Industry Regulatory Authority (“FINRA”) is doing social-media compliance spot checks on some of its member firms. In a notice posted Monday on FINRA’s website, the regulator said it wants broker-dealers to identify the sites used by a firm, as well as all individuals who post or update the firm’s content on social-media sites.

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How Does Your Bank Handle Customer Requested Maintenance Changes?

Posted by OnCourse Staff June 25, 2013 12:04pm
Sample Image Photo Credit: ctoocheck

Throughout my observation and experience auditing different community banks in the northeast, it seems that there are different methodologies with regards to maintenance changes on a customer’s account(s). Some may see the function as quite effortless, but viewing it from the customer’s point of view may change that mindset.

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OCC Releases Booklet on "Common Sense" Community Banking

Posted by OnCourse Staff June 20, 2013 12:08pm
Sample Image Photo Credit: ppdigital

The Office of the Comptroller of the Currency yesterday released a booklet called “A Common Sense Approach to Community Banking,” in which it outlines the regulator’s view of how community banks can thrive.

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New SAR Filing Updates

Posted by OnCourse Staff June 4, 2013 2:37pm
Sample Image Photo Credit: Rawich

FinCEN’s new Suspicious Activity Report (“SAR”) form, which was made mandatory as of April 1, 2013, now contains check box items for various key terms in order to help the Federal government identify individuals, groups and organizations involved in fraud, terrorist financing, money laundering, and other crimes.

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Is your BSA/AML automated monitoring system up to par?

Posted by OnCourse Staff June 4, 2013 2:11pm
Sample Image Photo Credit: Victor Habbick

On April 4, 2011, the Office of the Comptroller of the Currency published supervisory guidance on Model Risk Management. The purpose was to provide comprehensive guidance for banks on effective model risk management. The use of models invariably presents model risk, which is the potential for adverse consequences from decisions based on incorrect or misused model outputs and reports. The essence of this guidance is that “garbage in results in garbage out”.

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The Importance of BSA Training

Posted by OnCourse Staff May 28, 2013 5:44pm
Sample Image Photo Credit: Barky

As required by the Bank Secrecy Act, all Bank employees should understand the purpose and importance of BSA training. It is believed that continued compliance with BSA helps the Bank build an important weapon against the war on terrorism.

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Sample Image Photo Credit: altankoman

On February 5, 2013, the Office of Foreign Assets Control introduced the first SDN list search tools which employ a “fuzzy” logic search option. For those of you that don’t know, “fuzzy” logic is a search option that deals with reasoning that is approximate rather than fixed or exact. The OFAC SDN Fuzzy logic search tool uses “character and string matching as well as phonetic matching.

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Filing the New CTR Forms: What you need to Know

Posted by OnCourse Staff February 26, 2013 5:04pm
Sample Image Photo Credit: najit.org

Beginning on April 1, 2013, the new FinCEN CTR forms will be mandated. Older versions of the reports will not be accepted into the E-filing system after March 31, 2013. In addition, the new filing requirement will eliminate the 25 days allowed for electronic filing. New filings must be submitted within 15 days of the date of the transaction.

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FFIEC Proposed Risk Management Guidance on Social Media: Beware and Prepare

Posted by OnCourse Staff February 15, 2013 5:27pm
Sample Image Photo Credit: Lalie F

The Federal Financial Institutions Examination Council (FFIEC) released on January 22, 2013 the proposed guidance on Social Media use in response to requests from various industries and interest groups to assist them in understanding the risks associated with social media activities. According to the press release, the guidance is not an additional imposition to financial institutions. Rather, it is meant as a standardized basis for managing social media exposures for institutions that need it.

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Solutions to Reducing Dormant Accounts at Your Institution

Posted by OnCourse Staff February 8, 2013 12:03pm
Sample Image Photo Credit: Kittikun

Unclaimed property is governed by state laws. Although each state may be a little different in its requirements, all will require you to escheat unclaimed property to the state after a certain length of time where you have not had contact with your customer.

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Pandemic Preparedness: Are you testing your Pandemic Plan?

Posted by OnCourse Staff February 5, 2013 3:21pm
Sample Image Photo Credit: scottchan

Many institutions including Banks and financial institutions are required by state and federal regulatory agencies such as the Federal Financial Institutions Examination Council (FFIEC) and the Federal Deposit Insurance Corporation (FDIC) to develop and implement a Pandemic Plan for business continuity.

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Regulation E Foreign Remittance Rules

Posted by OnCourse Staff January 18, 2013 5:17pm
Sample Image Photo Credit: morguefile.com

Regulation E Foreign Remittance Rules go into effect February 7, 2013 as promulgated by the CFPB (Consumer Financial Protection Bureau). These rules can be found in Subpart B of Regulation E (12CFR Chapter X part 1005). There are a lot of related tools located on the CFPB’s website that can also give you more information. You can click this link. The CFPB has also posted a free webinar video that you can watch that will give you all of the rules and help you determine if you will be subject to these rules.

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FFIEC issues revised “Supervision of Technology Service Providers” booklet

Posted by OnCourse Staff December 14, 2012 4:47pm
Sample Image Photo Credit: adamr

The Federal Financial Institutions Examination Council (FFIEC) issued a revised “Supervision of Technology Service Providers” booklet (TSP booklet), which is one of the booklets in the FFIEC Information Technology Examination Handbook (IT Handbook). Concurrently, the Board of Governors of the Federal Reserve System (FRS), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) issued new “Administrative Guidelines - Implementation of Interagency Programs for the Supervision of Technology Service Providers” (Guidelines).

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Expiration of Unlimited Deposit Insurance for NIBTAs

Posted by OnCourse Staff December 10, 2012 4:01pm
Sample Image Photo Credit: vichie81

I realize this article is coming out a little late, however, for those banks that are not yet prepared, you still have time to show the regulators that you have prepared for the December 31, 2012 expiration. While there is still a small chance that the regulatory agencies will choose to extend the Insurance program as it pertains to Non-Interest Bearing Transaction Accounts (NIBTA), we are getting closer to the December 31, 2012 expiration date with no word on any extension.

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Is Your Institution's Marketing UDAAP Compliant?

Posted by OnCourse Staff November 12, 2012 11:32am
Sample Image Photo Credit: sumetho

How many of you saw this headline recently? “Discover to refund $200 Million to customers for deceptive telemarketing.” If you missed it, the long and short of it was that Discover violated the principles of UDAAP and the FDIC, and CFPB brought the hammer down.

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What is Enterprise Risk Management?

Posted by OnCourse Staff October 5, 2012 4:26pm
Sample Image Photo Credit: Idea go

Look up in the sky...is it a bird? is it a plane? No! Duh, it’s ERM! Yes, ERM: the new mantra in community banking. And it’s confusing as heck. “What is ERM?” “How do you know if you see it?” These are two questions that have been making bankers scratch their heads lately.

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New OCC Guidance Released on Investor Owned Properties

Posted by OnCourse Staff October 2, 2012 11:07am
Sample Image Photo Credit: phanlop88

The Office of the Comptroller of Currency (“OCC”) has released new guidelines on credit risk management practices for investor-owned, 1-4 family residential real estate lending where the primary repayment source for the loan is the rental income generated by that property.

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Electronic Work Papers - Why P&G Made the Switch

Posted by OnCourse Staff September 25, 2012 10:30am
Sample Image Photo Credit: nuttakit

While the concept of electronic workpapers is not an entirely new concept (in development for the past 10 years), it has been steadfastly increasing in its recent growth and assimilation into businesses, most especially in accounting and financial companies, and has proven to be an effective and cost efficient tool in every day processes.

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Sample Image Photo Credit: Stuart Miles

The United States Senate Permanent Subcommittee on Investigations (“PSI”) attributed HSBC’s ineffective and/or inadequate anti-money laundering policies and procedures to lax regulatory oversight. HSBC was cited by the OCC in 2010 for multiple AML deficiencies, including...

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Clarifying Regulatory Obligations Regarding Continuing Activity SAR Filings

Posted by OnCourse Staff September 14, 2012 2:05pm
Sample Image Photo Credit: Michaelaw

The Financial Crimes Enforcement Network published guidance in the May 2012 “The SAR Activity Review: Trends, Tips, & Issues, Issue 21”, which clarifies regulatory obligations for financial institutions regarding continuing activity SAR filings.

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Federal Regulatory Agencies Proposal New Rule

Posted by OnCourse Staff September 12, 2012 10:19am
Sample Image Photo Credit: dsnews.com

Recently, the six “heavy hitters” of the federal regulatory agencies (i.e., The Federal Reserve, OCC, CFPB, FDIC, FHFA, and NCIA) jointly proposed a new rule to institute additional appraisal requirements for what are defined as "higher-risk mortgage loans." The proposal would enact clauses to the Truth in Lending Act made into law by the sweeping Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.

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Risk management - Smaller institutions and the benefits of ERM

Posted by OnCourse Staff September 11, 2012 5:30pm
Sample Image Photo Credit: 123rf

Smaller institutions with simple business models may be somewhat skeptical about the benefits to be derived from implementing a broad-scale, and possibly costly, enterprise risk management program.
Nonetheless, the regulatory mandates on ERM seem to be “trickling down,” affecting ever-smaller institutions as regulators push hard for it’s implementation - even though the Dodd-Frank mandate is directed at institutions with more than $10 billion in assets.

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Strengthening Your Loan Maintenance Monitoring

Posted by OnCourse Staff September 6, 2012 1:11pm
Sample Image Photo Credit: vichie81

When my team and I visit a client to perform an engagement, there are usually a variety of tasks that we will perform during one audit. Some, such as the Allowance for Loan Loss, are considered high risk by everyone, and taken quite seriously wherever we go. Senior management always looks for feedback or how to strengthen their existing controls.

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New Lending Proposal from CFPB

Posted by OnCourse Staff August 27, 2012 4:44pm
Sample Image Photo Credit: Stuart Miles

On August 17, 2012, The Consumer Financial Protection Bureau (“CFPB”) proposed new mortgage origination requirements that are designed to bring “greater accountability to the mortgage loan origination market.“

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FDIC Reaches Settlement on Overdraft Fees

Posted by OnCourse Staff August 21, 2012 1:01pm
Sample Image Photo Credit: David Castillo Dominici

The Federal Deposit Insurance Corporation (“FDIC”) sent out a release on August 8, 2012, stating that it has reached financial settlement terms with a Bank and its affiliate over alleged violations of the Federal Trade Commission Act (“FTC Act”).

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FRB Guidance on Foreclosures

Posted by OnCourse Staff August 3, 2012 12:13pm
Sample Image Photo Credit: NoBo Magazine

The Federal Reserve Board recently issued guidance regarding risk management controls and procedures in situations where banks have made a decision not to follow through with foreclosure proceedings after they have been started.

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Loan Denials and Withdrawals – Tips to Sure Up your Process

Posted by OnCourse Staff July 30, 2012 1:14pm
Sample Image Photo Credit: linusb4

In the past few months, my team and I have noted an increase in our recommendations to our clients for monitoring and documenting Withdrawn and Denied loans.

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Getting Enterprise Risk Management out of the Way of Doing Business

Posted by On Course Staff July 24, 2012 2:31pm
Sample Image Photo Credit: NJBankers12

Jack Warnock of P&G Associates shares how to effectively include Enterprise Risk Management in daily business operations.

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Regulation O – 5 Easy ways to avoid violations

Posted by OnCourse Staff July 12, 2012 9:50am
Sample Image Photo Credit: freedigitalphotos.net

Regulation O covers transactions between the financial institution and their insiders (directors, executive officers, and related interests). Regulation O limits the extensions of credit to these insiders in a number of ways.

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The Summer of CFPB Proposals

Posted by OnCourse Staff July 11, 2012 11:26am
Sample Image Photo Credit: FreeDigitalPhotos.net

The Consumer Financial Protection Bureau ("CFPB") is proposing Consumer Mortgage related changes faster than summer releases at the box office. Here is a summary of the latest that have come down the pipe from on high:

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Sample Image Photo Credit: FreeDigitalPhotos.net

Mortgagebot has tracked a growing trend by small mortgage lenders to adopt web-based, transactional online lending technology as a way to narrow big lenders' competitive advantages by creating greater visibility and accessibility in the online channel at affordable cost.

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Dodd-Frank Rule to Change Legal Lending Limit Monitoring Requirements

Posted by OnCourse Staff June 27, 2012 11:36am
Sample Image Photo Credit: FreeDigitalPhotos.net

The Office of the Comptroller of the Currency (“OCC”) has issued an interim final rule amending its lending limit rule to apply to certain credit exposures that were not considered as part of the legal lending calculation previously.

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The ABCs of a TDR

Posted by OnCourse Staff June 21, 2012 11:11am
Sample Image Photo Credit: freedigitalphotos.net

One of the biggest open questions my team sees in the field during our examinations is exactly how to assess our clients’ process for handling Troubled Debt Restructures ("TDR").

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The Supreme Court of the United States issued a rare unanimous ruling May 24, 2012 that resolves early lower court divided decisions, stating that a violation of Section 8(b) of the Real Estate Settlement Procedures Act ("RESPA") happens only when...

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Sample Image Photo Credit: Stuart Miles

The Financial Crimes Enforcement Network has issued guidance as of March 16, 2012 to clarify for currency transaction reporting purposes, the aggregation of multiple transactions conducted by businesses with common ownership.

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Sample Image Photo Credit: FreeDigitalPhotos.net

On May 9, 2012, Rep. Carolyn Maloney (D-NY), senior member of the House of Financial Services Committee, along with 46 cosponsors, introduced the “Overdraft Protection Act” which would amend the manner in which overdraft fees are collected.

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Sample Image Photo Credit: Rawich

According to a notice issued by the Financial Crimes Enforcement Network dated February 24, 2012, financial institutions subject to Bank Secrecy Act reporting will be required to use electronic filing (E-Filing) for certain FinCEN reports beginning no later than July 1, 2012.

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Curry: Operational Risk Now OCC’s Top Concern

Posted by OnCourse Staff May 17, 2012 11:16am
Sample Image Photo Credit: Michelle Meiklejohn

Operational risk has eclipsed credit risk as national banks’ chief safety and soundness challenge, Comptroller of the Currency Thomas Curry told the Exchequer Club in Washington, D.C., yesterday.

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JOBS Act Client Alert - Rules 506 of Regulation D

Posted by OnCourse Staff May 11, 2012 2:48pm
Sample Image Photo Credit: Stuart Miles

The JOBS Act (the “Act”), signed into law on April 5, 2012, promises to have a significant impact on two popular exemptions to registration of securities under federal securities laws. Currently, any issuer intending to rely on either Rule 506 of Regulation D or Rule 144A cannot engage in any general solicitation or advertising to attract investors.

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New Rules Proposal for Servicers Coming from the CFPB

Posted by OnCourse Staff May 3, 2012 4:24pm
Sample Image Photo Credit: scottchan

Our new best friends, The Consumer Financial Protection Bureau (“CFPB”) is preparing to issue rules proposals for loan servicers regarding the criteria and timeliness of the information flow to consumers.

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Wall Street Receives Volcker Rule Clarity

Posted by OnCourse Staff April 30, 2012 3:50pm
Sample Image Photo Credit: jscreationzs

Wall Street can exhale. Regulators on Thursday announced a formal clarification that Wall Street need not immediately comply with a new rule banning banks from trading with their own money, sending sighs of relief across the financial industry. The guidance, delivered by the Federal Reserve and other financial regulators, explained that the Dodd-Frank regulatory overhaul law grants banks two years to fully comply with the Volcker Rule, which regulators have yet to finalize.

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De-stressing with stress testing

Posted by OnCourse Staff March 29, 2012 4:26pm
Sample Image Photo Credit: morguefile.com

Headlines about the financial crisis tend to focus on the subprime mortgage collapse, but the impact of the crisis on the banking industry has spread well beyond residential lending. The biggest area of concern is commercial real estate (CRE) lending. Many community banks have high concentrations of CRE loans in their portfolios, so it’s critical to assess your risk exposure in connection with these loans and take steps to manage that risk.

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Banks Participate in Information Sharing to Battle Online Theft

Posted by OnCourse Staff January 12, 2012 3:15pm
Sample Image Photo Credit: iStockPhoto

For years, financial institutions shuddered at the thought of ever sharing information with one another, and always opted to maintain internal research for fears of providing “too much insight” into the other’s daily operations.

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IT security: Is your program still effective?

Posted by OnCourse Staff January 5, 2012 3:00pm
Sample Image Photo Credit: BankWire

As online banking services become more sophisticated and more widely used, IT security measures that were effective only a few years ago may no longer be enough.

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Banking Solutions: ALLL and GAAP in Agreement

Posted by OnCourse Staff November 30, 2011 3:17pm
Sample Image Photo Credit: BankSolu11

I wanted to share an article that I wrote for a recent publication of the Banking Solutions 2011 Magazine, an annual Bankers' information guide that features special technology and services relative to the world of banking.

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Sample Image Photo Credit: MorgueFile.com

For many community banks, they have been significantly impacted by the current economic environment. The low interest rates, coupled with lower lending demand, has already lowered the earning base for many. But what is impacting them the most, and affecting their profitability, is their ability to meet the evolving and increased regulatory emphasis and regulations.

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Sample Image Photo Credit: 123RF

Over the past few years, the banking industry has been entrenched in a very volatile economic and regulatory environment. The number of regulatory enforcements and bank closings over the past three years have been astronomical. These actions have resulted in a very demanding regulatory environment that places a significant amount of pressure on banks, especially community banks.

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Mobile banking: How do we get there?

Posted by OnCourse Staff October 12, 2011 11:51am
Sample Image Photo Credit: intomobil

With the advent of the smartphone and tablet computer, mobile banking has become the next step in the evolution of online banking. Many banks now allow customers to access their accounts, make transfers and payments, and conduct other transactions - all from their mobile devices.

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UBS further struggles with $2 Billion loss by Rogue Trader

Posted by OnCourse Staff September 16, 2011 2:17pm
Sample Image Photo Credit: ctoocheck

To make matters worse, UBS revealed that a rogue trader reportedly lost $2 billion in assets. London officers suspect European equities trader and UBS employee, Kwek Adoboli, to be in connection with the case and have arrested him, per an unknown source.

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Capital One Becomes Dodd-Frank Test as Nation’s Fifth Largest Bank

Posted by OnCourse Staff August 25, 2011 4:18pm
Sample Image Photo Credit: 4seasons

What does Capital One have in common with Goldman Sachs, Morgan Stanley and Bank of America? It may soon be dubbed as yet another bank that is “too big to fail.” Capital One is in the middle of a $9.2 billion purchase of the online bank, ING Direct, which, if successful, could potentially make Capital One (with currently over $200 billion in deposits), the fifth largest bank in the United States.

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Community Banks to receive US Funding for Small Businesses

Posted by OnCourse Staff August 5, 2011 3:58pm
Sample Image Photo Credit: freestock.com

Last September 2010, Congress created a program in an effort to help community banks provide more loans to small businesses and have enacted such into law as part of the Small Business Jobs Act of 2010, titling such as the Small Business Lending Fund (“SBLF”).

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FDIC fields questions about overdraft guidance

Posted by OnCourse Staff July 28, 2011 4:14pm
Sample Image Photo Credit: Banking Advisor

The FDIC’s guidance on overdraft fees may be less strict than many bankers feared, according to the agency’s recently published FAQs on supervisory guidance, which was issued by the agency in November.

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Negligent Hiring – A mistake can cost more than just money!

Posted by OnCourse Staff July 21, 2011 5:40pm
Sample Image Photo Credit: Chodra

Every executive I know has a few reoccurring nightmares. As a Human Resources professional, I have a few as well. My nightmare is this: I wake up on beautiful sunny morning and head to the kitchen for my favorite cup of coffee. I still have on my pjs and slippers, and my dogs by my side. I open my morning newspaper and there it is, right on page one. It hits me between the eyes, like a bullet, and there is nothing I can do to stop it. I drop my coffee mug, with the hot liquid burning my leg. I look again at the first page of the newspaper and, in bold print splashed across the top, the headline reads: EMPLOYEE OF [YOUR COMPANY] ACCUSED OF...

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Regulatory Burden – Managing the Pain

Posted by OnCourse Staff July 12, 2011 5:21pm
Sample Image Photo Credit: throbi

“If you have ever played the game of Jenga -- where you pull blocks from a tower and add them to the top -- you know that eventually the structure falls down. It can’t handle the twin pressures of lost foundational support and additional weight,” ABA Chairman-elect, Albert Kelly declared in one of his past posts in the ABA’s Washington Perspective. Personally, I love Jenga, even though my daughter beats me every time. Albert Kelly’s reference to Jenga when comparing the burden of new regulations and the onslaught of over reaching regulatory exams is perhaps an excellent analogy to describe the current landscape at the community banking level.

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Last Sunday morning, Gary Foster, a former Citigroup Inc. assistant vice president was arrested by Federal Bureau of Investigation agents after allegedly embezzling more than $19.2 million from Citi, an act dubbed by federal prosecutors as, “the ultimate inside job.”

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TDR or Not to TDR …Much Ado about Nothing?

Posted by OnCourse Staff June 13, 2011 3:20pm
Sample Image Photo Credit: shuttermon

I hear from a “few” people that tackling and managing Troubled Debt Restructuring (commonly known as “TDR”) is becoming confusing based on new accounting pronouncements and ever changing regulatory emphasis. We can argue all day whether we are labeling a loan a TDR properly or not, but perhaps we’re missing the main objective of the renewed attention to this area by regulators and accountants. At the end of the day, the issue really becomes the Allowance for Loan Loss Reserve. I don’t want to come off as a one trick pony who keeps talking about the ALLL all the time, but it’s true.

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Finding the Right Hire

Posted by OnCourse Staff June 1, 2011 6:03pm
Sample Image Photo Credit: Chodra

As a member of industry and fraternal organizations, I often get asked by people I know if I can help them find a job. Sadly, some of these individuals have been out of work for a year or more, making them members of the long-term unemployed. You can see the look of desperation as they actively look for their next opportunity. Many were laid off during the economic downturn, dubbed “The Great Recession”. I wish I could do more to help. Many of us know individuals in similar circumstances, feel bad and want to help. Then I come to the office and the exact opposite occurs: I can’t find qualified candidates for our open roles.

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Model behavior: Is your ALM model capturing your bank’s risks?

Posted by OnCourse Staff May 20, 2011 5:00pm
Sample Image Photo Credit: altankoman

Asset-liability management (ALM) is a critical activity for banks — not just for meeting regulators’ expectations, but also as a strategic tool for controlling risk and enhancing performance. In today’s high-risk environment, it’s critical for a bank’s board of directors or asset and liability committee to take a proactive approach to ALM. There are a variety of ALM modeling software programs available, ranging from simple spreadsheets to outsourced solutions and sophisticated, highly customized in-house systems. Here are some questions to ask as you evaluate your bank’s program.

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ALLL best practices: Pay attention to qualitative factors

Posted by OnCourse Staff May 18, 2011 3:35pm
Sample Image Photo Credit: StefanG81

Staying on top of the allowance for loan and lease losses (ALLL) is critical for banks, especially in the current economy. If examiners find that your ALLL is underfunded, they may downgrade your bank’s CAMEL rating, require you to increase capital levels or take other remedial action.

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Abandoned Property Law, and its new New York State of Mind

Posted by OnCourse Staff May 10, 2011 5:51pm
Sample Image Photo Credit: Barky

According to the Office of the New York State Comptroller, all banks, insurance companies, corporations, and courts are required to report their dormant accounts. Per the law, such institutions must adhere to specific guidelines during the reporting process in order to ensure that the State’s database can remain current and consolidated with all required information.

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Sample Image Photo Credit: SimonOk

Unless you’ve been living under a rock for the past few years, you’ve probably heard of a trojan known as Zeus. It is often referred to as the "Man-in-the-Browser" because it begins by infecting the customer, not the institution. It takes advantage of vulnerabilities on a customer’s computer and waits for the customer to connect to an institution’s website. Once the customer connects, the trojan is capable of detecting that the customer is browsing a financial institution’s website and can silently make transactions in the background. It can also alert the attacker in real-time so that the attacker can hijack the customers session and manually perform transactions of his own.

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FDIC releases Provisions on Dodd-Frank to help Community Banks

Posted by OnCourse Staff May 2, 2011 3:36pm
Sample Image Photo Credit: PhotoEverywhere.co.uk

Last Friday, the Federal Deposit Insurance Corporation (“FDIC”) released a white paper detailing nine Dodd-Frank Act provisions believed to, despite existing concerns, prove beneficial to community banks. According to the FDIC, these provisions were “designed to address questionable practices of certain non-bank financial services providers and to provide a greater oversight of the largest financial institutions to bring stability to the banking system.”

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Social Media in the Employment Arena – It Gets Funky!

Posted by OnCourse Staff April 26, 2011 11:53am
Sample Image Photo Credit: Milalie F.

There are very legitimate business needs and benefits for companies to utilize social media. Those that do not utilize the advantages can be missing a huge opportunity to connect with clients and vendors in a very meaningful way. However, it also contains a snake pit of risk as it pertains to the employee/employer relationship. To make matters more complicated, the law and company policies cannot keep up with advances in technology. With social media and employment, it’s gets funky - especially when events that transpire outside of the workplace creep into the workplace.

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The Proof is in the Pudding: Affects of Dodd-Frank on Community Banks

Posted by OnCourse Staff April 13, 2011 4:40pm
Sample Image Photo Credit: aduhai

We all know that a glass containing some water can be described as either “half-full” or “half-empty”. Until recently, I chose to describe the Dodd-Frank bill as half empty. In fact, I was pretty vocal about the impact of regulatory burden on community banks. It wasn’t until last Wednesday afternoon when I converted.

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Banks and Businesses get "swiped" over Fees

Posted by OnCourse Staff April 6, 2011 4:21pm
Sample Image Photo Credit: Intuitives

Last week, the battle between banks and businesses continued over rules on whether the fees charged by banks should be limited when processing debit card transactions. While banks and financial institutions are fighting for Congress to effect the Dodd-Frank rules, grocery store and various retail store merchants stormed on Capitol Hill in an effort to postpone the Dodd-frank requirements.

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Sample Image Photo Credit: Ambro

The Federal Reserve on Thursday released a collection of 25,000 emergency-lending documents detailing the Banks that sought for financial help during the economic downturn of 2008.

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IT Security: "IT's" About Process

Posted by OnCourse Staff March 30, 2011 1:36pm
Sample Image Photo Credit: Rawich

Effective corporate governance is perhaps the single most effective security control in an institution. In community financial institutions, it is usually the responsibility of the audit or supervisory committee to hold management accountable for the decisions they make. That includes holding the information security officer accountable for the security issues identified as part of internal audits and security assessments. An audit committee can have a very positive, or negative impact on organizational security, which will largely be a function of how capable the committee is at managing an area that has quickly evolving threats and risks.

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To Test or Not to Test; That is the Question

Posted by OnCourse Staff March 24, 2011 11:14am
Sample Image Photo Credit: Miguelima

Employee testing is a controversial topic. Ask five people their stance on this topic and you will get five different, often heated opinions. Business owners, executives, and managers tend to respond in the pro-testing camp, citing customer protection, business intelligence, and other employee’s welfare as justification. Employees, government agencies, and activist groups tend to respond in the anti-testing camp, citing employee privacy, data protection, and employee rights against discrimination as reasons not to test. So, the question is: to test or not to test employees?

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2011 Failed Bank List Hits 25

Posted by OnCourse Staff March 16, 2011 3:51pm
Sample Image Photo Credit: Legacy Bank

Regulators this past Friday, March 11, closed two financial institutions: Legacy Bank of Milwaukee, WI and The First National Bank of Davis in Davis, OK.

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Wag the Dog

Posted by OnCourse Staff March 9, 2011 11:57am
Sample Image Photo Credit: Gideon Geldenhuys

It is the financial institution’s responsibility to secure the network and the data that resides therein. A common attitude that I see in community financial institutions is that the institutions only feel obligated to implement security insofar as the regulators have issues. In other words, many institutions will balk at the idea of implementing controls, and spending money, until the regulators demand it. That thought process is fundamentally incorrect.

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Sample Image Photo Credit: US HoR

The United States House of Representatives' Committee on Financial Services will hold a hearing today, March 2nd, on the effects of the Dodd-Frank Act on both small financial institutions and small businesses.

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2011 Failed Bank List up to 18

Posted by OnCourse Staff February 17, 2011 10:44am
Sample Image Photo Credit: The Hamtramck Review

As of this past Valentine's Day, the 2011 Failed Bank list has grown to 18. Thus far, bank failures are on a similar course to 2010, which had 16 failures at this point in the year.

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A Culture of Whatever: On the Path to Proper Governance

Posted by OnCourse Staff February 15, 2011 10:26am
Sample Image Photo Credit: jscreationzs

We knew it would happen eventually. The FDIC is now seeking to get aggressive in seeking money from the “bad” guys. Its 2011 budget in fact shows a significant increase in staffing to handle the planned increased litigation. While we don’t know for sure, it is estimated that the FDIC will spend in excess of $50 billion in the closing of failed banks. This is in addition to the approximately $57 billion it has already spent during this crisis. That’s a hefty number.

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The Test Drive: Leasing or Buying a HR IT Platform

Posted by OnCourse Staff February 11, 2011 3:09pm
Sample Image Photo Credit: spekulator

Question: Do you Lease or Buy a HR IT platform?

Answer: Depends on your HR IT Strategy.

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Detective, Reactive and Preventive: Evolving Your IT Security

Posted by OnCourse Staff February 8, 2011 5:10pm
Sample Image Photo Credit: clix

In my The Credit – Er, IT Crisis post I talked about some of the forces influencing security in community banking. One of the forces I mentioned was that the audit process has remained largely the same, while at the same time, the IT environments of modern banks are rapidly evolving. But what does that mean? Given the evolving environment, how does the audit process have to evolve to ensure the information security of a community bank? What does a community bank need to do to complement the audit process?

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Cracking the ALLL Code: How to Develop the Right FAS 114 Methodology

Posted by OnCourse Staff February 2, 2011 3:41pm
Sample Image Photo Credit: Leonardo da Vinci

Now that we’ve mastered the art of calculating an appropriate ASC 450 (FAS 5) Reserve balance, it is time to take on a bigger challenge. And what could be a bigger challenge than developing a systematic and objective methodology to calculate the ASC 310 (FAS 114) reserve balance for your institution? Well, getting your kids to stop texting while eating dinner … probably. If you can do that, then ASC 310 will be child’s play for you.

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Double Digits: Bank Closings up to 11 in 2011

Posted by OnCourse Staff February 1, 2011 2:24pm
Sample Image Photo Credit: FirsTier Bank

Regulators on Friday (January 28) closed four institutions: $2.3 bil-asset First Community Bank of Taos, NM; $43 mil-asset First State Bank of Camargo, OK; $246 mil-asset Evergreen State Bank of Stoughton, WI; and the $781 mil-asset FirsTier Bank of Louisville, CO.

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FCIC Releases Report on the Causes of the Financial Crisis

Posted by OnCourse Staff January 28, 2011 11:45am
Sample Image Photo Credit: FCIC

The Financial Crisis Inquiry Commission released their long-awaited report on the Causes of the Financial Crisis yesterday (January 27th). The near-meltdown of the financial system is reported to have had many causes, and could have been prevented had there not been widespread failures in financial regulation.

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Part of the In Crowd: Thoughts on the Dodd-Frank Act

Posted by OnCourse Staff January 25, 2011 1:40pm
Sample Image Photo Credit: Robert Linder

In my attempt to master the business of social media, I recently posted a poll to several hundred (may actually be thousands) of banking professionals that are probably much better at this than I am. The question that was the focus of the poll was: Is the Dodd Frank Bill adequate to control the systemic risk of financial institutions both large and small?

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Another One Bites the Dust: Regulators Close 4 Banks

Posted by OnCourse Staff January 25, 2011 1:14pm
Sample Image Photo Credit: David Sharkbone

Regulators on Friday (January 21) closed four banks: $2 billion- asset United Western Bank of Denver, CO; $195.1 million-asset The Bank of Asheville - Asheville, NC; $440.6 milllion-asset CommunitySouth Bank & Trust - Easley, SC and $100.9 million-asset Enterprise Banking of McDonough, GA. This brings the 2011 failed bank total to 7.

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Keeping the Balance: IT Security and the Org Chart

Posted by OnCourse Staff January 24, 2011 4:05pm
Sample Image Photo Credit: Felipe Horst

One of the most difficult things for a community bank to do is to balance the efficiency we need from IT - with the security IT requires. Efficiency and security have an inverse relationship to one another. You can have high efficiency or high security, but not both. It’s like an old scale or a children’s seesaw. As security controls of a system are increased, the efficiency gained from the system decreases – and vice versa. For example, I can be really secure by unplugging my Internet connection from the wall, but it’s not very practical and certainly wouldn’t be very efficient.

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On Notice: FDIC Issues Rule for Temp Unlimited Deposit Insurance

Posted by OnCourse Staff January 20, 2011 11:48am
Sample Image Photo Credit: FDIC

As a result of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Board of Directors of the Federal Deposit Insurance Corporation ("FDIC") approved (on Tuesday, January 18), a final rule to include Interest on Lawyer Trust Accounts ("IOLTAs") in the temporary unlimited deposit coverage for noninterest-bearing transaction accounts.

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2011 Failed Bank List Up to 3

Posted by OnCourse Staff January 18, 2011 9:45am
Sample Image Photo Credit: Oglethorpe Bank

Oglethorpe Bank (of Brunswick, GA) was closed by the Georgia Department of Banking and Finance on Friday, with the FDIC as receiver.

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Welcome to OnCourse

Posted by OnCourse Staff January 14, 2011 4:01pm
Sample Image Photo Credit: Megan Hunter

Welcome one and all to OnCourse, a blog dedicated to providing you, the reader, a timely, informative and pertinent look at stories affecting the financial industry.

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Stick 'Em Up!

Posted by OnCourse Staff January 14, 2011 4:01pm
Sample Image Photo Credit: Boaz Yiftach

The FBI has released their 3rd quarter (2010) bank crime statistics for the period of July 1, 2010 through September 30, 2010. They report that during this period there were 1,325 reported violations - an increase from the 1,212 reported in 2009.

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Time for a Tune-Up: The Necessity of a HR Audit

Posted by OnCourse Staff January 14, 2011 1:36pm
Sample Image Photo Credit: Sailor John

Every 30,000 miles you bring your car in for an oil change and regular maintenance. Every year you get a physical examination. Every month you balance your checkbook. There are some things that we do on a regular basis to help ensure we are up to date (both financially and health-wise), everything is working the way it should, and to evaluate what, if any, changes and updates need to be made so we are prepared for the future.

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Visa Instituting Two-Tiered Debit Card Interchange Structure

Posted by OnCourse Staff January 12, 2011 11:21am
Sample Image Photo Credit: Logo Stage

Visa Inc. announced on Friday (January 7th), that it would develop a two-tiered interchange schedule.

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The First Failed Banks of 2011

Posted by OnCourse Staff January 11, 2011 9:36am
Sample Image Photo Credit: FDIC

Two banks were closed by regulators on Friday, January 7, 2011 - starting off the new year with the first new financial institution failures.

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The Credit -- Er, IT Crisis?

Posted by OnCourse Staff January 10, 2011 10:26am
Sample Image Photo Credit: Fred Goldstein

The credit crisis and subsequent recession got me thinking about the potential for a similar “IT crisis” in community banking.

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Painting a Masterpiece: The Art of the ALLL Reserve

Posted by OnCourse Staff January 10, 2011 10:26am
Sample Image Photo Credit: Johnny Berg

How do we define an adequate level of ALLL reserve? Alas, that is the new $64 question in the banking industry. The ALLL Reserve is apparently like a priceless art piece, which is subject to significant scrutiny and different interpretations.

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The Law on Your Side: Understanding HR Regulations in 2011

Posted by OnCourse Staff January 7, 2011 6:11pm
Sample Image Photo Credit: Jason Morrison

Many polls show that hiring will pick-up in 2011 as business conditions and the economic landscape improve. One recent poll has hiring increasing as much as 32%. Whereas this is welcome news, it does come with some warnings. Employment based lawsuits are also on the rise. The 2010 Chubb Private Company Risk Survey indicated that one in five respondents believed they will have an employment practices liability (EPL) lawsuit during 2011.

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Building a Better Hen House

Posted by OnCourse Staff December 13, 2010 6:33pm
Sample Image Photo Credit: Free Digitial Photos

For the banking industry, IT Security is an ever changing concern that must be addressed with the most recent threats in mind. For many institutions, security is handled by policy based IT audits and annual penetration tests performed by external vendors.

To truly prevent a fox from getting into your “hen house,” so to speak, you must go above and beyond penetration tests and policy based IT audits. Below is a recent conversation I had with “Joe Management” where I discuss one way to go above and beyond – the vulnerability assessment.

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Ready the Ramparts! : IT Security and the Modern Bank

Posted by OnCourse Staff December 13, 2010 4:56pm
Sample Image Photo Credit: Tom Curtis

From the Manhattan District Attorney's Office

"Manhattan District Attorney Cyrus R. Vance, Jr., today [September, 30th] announced the indictments of 36 individuals for their participation in several large-scale international identity theft and cybercrime rings that stole more than $860,000 from 34 separate corporate and individual victims in the United States. The defendants, foreign students who were in the United States on Exchange Visitor Visas, are charged with opening bank accounts at JP Morgan Chase Bank and other financial institutions in New York County and elsewhere, for the purpose of receiving fraudulent transfers from identity theft victims’ bank accounts. (District Attorney, 2010)".

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No Respite from RESPA

Posted by OnCourse Staff December 13, 2010 4:56pm
Sample Image Photo Credit: Bill Longshaw

The recent changes in regulatory compliance relative to the Real Estate Settlement Procedures Act (“RESPA”) have caused a significant level of concern and anxiety amongst bankers.

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OnCourse Staff

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Flood Coverage – Still a Hot Regulatory Issue
Interagency Statement on Sharing BSA Resources and Challenges
New Jersey's Corporate Business Tax Legislation: A Look at the Impact for Banks
Correspondent Banking: The Challenges of Data Transparency
Regulation E and Business Account Errors
Controls over Employee and Officer T&E Expenses
Is Regulation CC Put on the Back Burner?
Training – An Investment and Risk Management Tool
Are You Gambling with Your BSA Program?
The Case of Foreign Banks and Heightened Scrutiny
IRS and New Jersey Tax Audits of Banks
State Taxation of Financial Institutions in Today's Environment
Does your 401(k) Plan need an Audit?
De-Risking of Foreign Correspondent Banks
Same Day ACH Credits – Phase One
FinCEN Finalizes Ruling on Beneficial Ownership and Ongoing Customer Due Diligence
Keep an Eye On Your Chip!
Is the IRS Status of your Defined Benefit plan in Jeopardy?
The Dilemma of Banking Medical Marijuana Businesses and Other Indirect Risks
Is your Institution Monitoring Working Capital Lines of Credit?
Financial Reporting and Regulatory Update on the Horizon
BSA/AML Training: Is your program effective?
Planning in a Consolidating Banking Industry
To opt-out or not to opt-out, that is the question – A reminder on March 31, 2015 Call Report, Schedule RC-R, item 3.a
Anti-Money Laundering – The Age of Technology
Top Compliance Topics Discussed at the NJ Bankers Compliance University
Some tips and tricks for dealing with Regulatory Examinations
Updated Regulation E Booklet from the OCC!
Is Flood Disaster Still on the Heat Map?
Have You Implemented Your Plan yet?
FDIC Consumer Newsletter
More Flood Insurance Changes...
Same Sex Married Couples - Ensuring Equal Treatment – Announcement from Consumer Financial Protection Bureau
Truth in Lending (Regulation Z) Annual Threshold Adjustments (CARD ACT, HOEPA and ATR/QM)
FFIEC Releases Revised BSA/AML Examination Manual: So what’s new?
OFAC Consolidates Non-SDN Listings
Coping with HOPA
Coping with the CFPB’s Ability-to-Repay Rule
ABA Survey on Impact of Dodd Frank Compliance
ABA Mortgage Origination Deskbook
Who handles Your Dormant Accounts?
Appraisal Disclosure Rule
Cybercriminals Broaden their Attacks in Social Networks
The Importance of Segregating a Bank’s Credit Function from its Lending Function
Appraisal Management Companies in Regulatory Crosshairs
All About the Home Owners Protection Act
Requesting Current Financial Information
Countdown to Windows XP End of Life and Support: Are you still at Risk?
314(b) Distinct Advantages for Financial Institutions
Where is the Document?
Building a Better Hen House
Ready the Ramparts! : IT Security and the Modern Bank
The Credit -- Er, IT Crisis?
Keeping the Balance: IT Security and the Org Chart
IT Security: "IT's" About Process
Wag the Dog
Consumerization of Technology and its influence on Information Security
Detective, Reactive and Preventive: Evolving Your IT Security
Do You Know The Security Features of the New $100 Bill?
Segregation of Duties for Wire Transfer Processing
How do you charge Early Withdrawal Fees on Time Deposits?
Do you still offer NOW Accounts?
Policy Changes Required – Do you Wait until Annual Approval?
Summarizing ACAMS White Paper on EDD and AML Risk Assessments (Industry Survey)
ACAMS to provide Free Webinar
ACBB Changes its Name
Who Do You Give Cash to?
ABA Briefing to Help Banks Address Cyber-security Threats
The OCC Issues Booklet: “A Common Sense Approach to Community Banking”
Safe Deposit Box Contents are not insured – But They COULD Be!
Allowance for Loan Loss Tips and Tricks
FDIC Can Review New Products
Let’s Talk About Overdrafts!
Community Banks Slowly Warm Up to Private Student Loans
Has your Bank updated the Adverse Action Notice?
Regulation E and NACHA Rules: When you Want to Stop Payment on a Recurring Debit
CFPB Stands Up Against Poor Debt Collection Practices
Don’t Forget the Small Stuff
Double Endorsed Checks: What is the Risk?
Social Media – Will the Regulators Do Spot Checks?
How Does Your Bank Handle Customer Requested Maintenance Changes?
OCC Releases Booklet on "Common Sense" Community Banking
New SAR Filing Updates
Is your BSA/AML automated monitoring system up to par?
The Importance of BSA Training
Office of Foreign Assets Control (“OFAC”) introduces the OFAC SDN Fuzzy Logic Search Tool
Filing the New CTR Forms: What you need to Know
FFIEC Proposed Risk Management Guidance on Social Media: Beware and Prepare
Solutions to Reducing Dormant Accounts at Your Institution
Pandemic Preparedness: Are you testing your Pandemic Plan?
Regulation E Foreign Remittance Rules
FFIEC issues revised “Supervision of Technology Service Providers” booklet
Expiration of Unlimited Deposit Insurance for NIBTAs
Is Your Institution's Marketing UDAAP Compliant?
What is Enterprise Risk Management?
New OCC Guidance Released on Investor Owned Properties
Electronic Work Papers - Why P&G Made the Switch
OCC to Toughen Exams in Response to United States Senate Permanent Subcommittee On Investigations
Clarifying Regulatory Obligations Regarding Continuing Activity SAR Filings
Federal Regulatory Agencies Proposal New Rule
Risk management - Smaller institutions and the benefits of ERM
Strengthening Your Loan Maintenance Monitoring
New Lending Proposal from CFPB
FDIC Reaches Settlement on Overdraft Fees
FRB Guidance on Foreclosures
Loan Denials and Withdrawals – Tips to Sure Up your Process
Regulation O – 5 Easy ways to avoid violations
The Summer of CFPB Proposals
Community Lenders Seize Market Share From Big Banks by Using Advanced Online Lending Technology
Dodd-Frank Rule to Change Legal Lending Limit Monitoring Requirements
The ABCs of a TDR
Supreme Court ruling for the Freeman, et al. v. Quicken Loans, Inc case
New FinCEN Guidance for CTR Aggregation for Businesses with Common Ownership (FIN – 2012 –G001)
Senior member of House of Financial Services Committee Introduces Overdraft Protection Act
FinCEN is looking to streamline the financial institution reporting process by issuing mandatory E-filing reporting requirements.
Curry: Operational Risk Now OCC’s Top Concern
JOBS Act Client Alert - Rules 506 of Regulation D
New Rules Proposal for Servicers Coming from the CFPB
Wall Street Receives Volcker Rule Clarity
De-stressing with stress testing
Banks Participate in Information Sharing to Battle Online Theft
IT security: Is your program still effective?
Banking Solutions: ALLL and GAAP in Agreement
How are the most recent regulatory enforcement trends that banks are facing today affecting internal audit? Why?
What are the most recent regulatory enforcement trends that banks are facing today?
Mobile banking: How do we get there?
UBS further struggles with $2 Billion loss by Rogue Trader
Capital One Becomes Dodd-Frank Test as Nation’s Fifth Largest Bank
Community Banks to receive US Funding for Small Businesses
FDIC fields questions about overdraft guidance
Negligent Hiring – A mistake can cost more than just money!
Regulatory Burden – Managing the Pain
From Embezzlement to Imprisonment: Former Citigroup employee faces charges with $19.2 million in bank fraud
TDR or Not to TDR …Much Ado about Nothing?
Finding the Right Hire
Model behavior: Is your ALM model capturing your bank’s risks?
ALLL best practices: Pay attention to qualitative factors
Abandoned Property Law, and its new New York State of Mind
Consumerization of Technology and its influence on Information Security
FDIC releases Provisions on Dodd-Frank to help Community Banks
Social Media in the Employment Arena – It Gets Funky!
The Proof is in the Pudding: Affects of Dodd-Frank on Community Banks
Banks and Businesses get "swiped" over Fees
A little bit of this, and a little bit of that: Fed Unveils list of Banks Helped during Financial Crisis of 2008
IT Security: "IT's" About Process
To Test or Not to Test; That is the Question
2011 Failed Bank List Hits 25
Wag the Dog
Committee on Financial Services to Hold Hearing on the Effects of Dodd-Frank on Small Biz and Banks Today
2011 Failed Bank List up to 18
A Culture of Whatever: On the Path to Proper Governance
The Test Drive: Leasing or Buying a HR IT Platform
Detective, Reactive and Preventive: Evolving Your IT Security
Cracking the ALLL Code: How to Develop the Right FAS 114 Methodology
Double Digits: Bank Closings up to 11 in 2011
FCIC Releases Report on the Causes of the Financial Crisis
Part of the In Crowd: Thoughts on the Dodd-Frank Act
Another One Bites the Dust: Regulators Close 4 Banks
Keeping the Balance: IT Security and the Org Chart
On Notice: FDIC Issues Rule for Temp Unlimited Deposit Insurance
2011 Failed Bank List Up to 3
Welcome to OnCourse
Stick 'Em Up!
Time for a Tune-Up: The Necessity of a HR Audit
Visa Instituting Two-Tiered Debit Card Interchange Structure
The First Failed Banks of 2011
The Credit -- Er, IT Crisis?
Painting a Masterpiece: The Art of the ALLL Reserve
The Law on Your Side: Understanding HR Regulations in 2011
Building a Better Hen House
Ready the Ramparts! : IT Security and the Modern Bank
No Respite from RESPA