Sunday, October 22, 2017

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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State Taxation of Financial Institutions in Today's Environment

Posted by Dennis 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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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 Pete 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 Pete 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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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 Pete 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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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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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 Pete 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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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 Pete 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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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 Pete 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 Pete 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

The OnCourse writing staff work to keep you informed about the most pertinent financial industry news of the moment



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Training – An Investment and Risk Management Tool
Are You Gambling with Your BSA Program?
Same Day ACH Credits – Phase One
Is the IRS Status of your Defined Benefit plan in Jeopardy?
Is your Institution Monitoring Working Capital Lines of Credit?
Financial Reporting and Regulatory Update on the Horizon
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
Cybercriminals Broaden their Attacks in Social Networks
The Importance of Segregating a Bank’s Credit Function from its Lending Function
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?
Do You Know The Security Features of the New $100 Bill?
Segregation of Duties for Wire Transfer Processing
Community Banks Slowly Warm Up to Private Student Loans
Has your Bank updated the Adverse Action Notice?
How Does Your Bank Handle Customer Requested Maintenance Changes?
OCC Releases Booklet on "Common Sense" Community Banking
New SAR Filing Updates
The Importance of BSA Training
FFIEC Proposed Risk Management Guidance on Social Media: Beware and Prepare
Pandemic Preparedness: Are you testing your Pandemic Plan?
FFIEC issues revised “Supervision of Technology Service Providers” booklet
Is Your Institution's Marketing UDAAP Compliant?
Electronic Work Papers - Why P&G Made the Switch
Community Lenders Seize Market Share From Big Banks by Using Advanced Online Lending Technology
New FinCEN Guidance for CTR Aggregation for Businesses with Common Ownership (FIN – 2012 –G001)
Curry: Operational Risk Now OCC’s Top Concern
JOBS Act Client Alert - Rules 506 of Regulation D
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?
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!
From Embezzlement to Imprisonment: Former Citigroup employee faces charges with $19.2 million in bank fraud
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
FDIC releases Provisions on Dodd-Frank to help Community Banks
Social Media in the Employment Arena – It Gets Funky!
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
To Test or Not to Test; That is the Question
2011 Failed Bank List Hits 25
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
The Test Drive: Leasing or Buying a HR IT Platform
Double Digits: Bank Closings up to 11 in 2011
FCIC Releases Report on the Causes of the Financial Crisis
Another One Bites the Dust: Regulators Close 4 Banks
On Notice: FDIC Issues Rule for Temp Unlimited Deposit Insurance
2011 Failed Bank List Up to 3
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 Law on Your Side: Understanding HR Regulations in 2011
No Respite from RESPA