Entries by Joel Lawrence

Strunk Response to January 2024 CFPB Proposed Changes to Overdraft Fees

In mid-January of this year, the Consumer Financial Protection Bureau (CFPB) proposed a new rule to restrict overdraft fees charged by very large financial institutions (Those with assets over $10B). View the PDF of the Proposed Rule with Request for Comment here: https://files.consumerfinance.gov/f/documents/cfpb_overdraft-credit-very-large-financial-institutions_proposed-rule_2024-01.pdf When the Board of Governors of the Federal Reserve System first adopted […]

Vendor Due Diligence Material Tracked in Strunk’s Vendor Manager Software

Financial institutions regulated by the OCC, FDIC, and Federal Reserve must conduct due diligence on third-party relationships per the Interagency Guidance on Third-Party Relationships: Risk Management. Regulators expect financial institutions to review vendor documents thoroughly rather than just glance over them. Organizing all your vendor management in a secure, web-hosted database is the first place […]

Importance of an Effective Contract Review

The Interagency Guidance of Third Party Risk Management states that an effective third-party risk management life cycle consists of planning, due diligence and third-party selection, contract negotiation, ongoing monitoring, and termination phase. One of the most critical aspects of the third-party life cycle is the contract negotiation phase. It is essential to evaluate a vendor’s contract with […]

How can Strunk’s software help with your vendor management program?

Regulators take compliance with vendor management regulations seriously due to the critical role third-party vendors play in delivering products and services. Using third-party services can increase the risk of a banking organization, but this does not mean that the organization can neglect its responsibility to perform all activities in a safe and sound manner. It […]

Consumers Continue Wanting Access to ODP

Consumers desire Overdraft Privilege as a financial product due to the wide array of choices available to them. In a Morning Consult survey, it was found that 9 out of 10 consumers consider their bank’s overdraft privilege valuable. So, what makes this product so valuable to consumers? Consumer’s payment will clear instead of being returned, […]

Vendor Management Breakdown

Over the years, banking partnerships with FinTechs have grown in number and complexity. Third-party risk management has become a growing focus for supervisory and enforcement agencies in recent years. To facilitate the increase in such relationships, the Board of the Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the […]

Defining Continuous Overdraft Fees

What exactly are continuous overdraft fees, and how could they potentially impact your Overdraft Privilege Program? It is important to be aware that certain financial institutions apply continuous overdraft fees, also known as daily overdraft fees. These fees are charged on a periodic or daily basis for as long as the account remains overdrawn. Currently, […]

How Can Strunk Assist with Vendor Management

When it comes to evaluating third-party risk management, financial institutions can use their own methods to determine the level of risk for each partnership. The regulators understand that not all relationships require the same level of scrutiny, and it is important to recognize vendors with high and critical risks. At Strunk, we have created a […]

Update on Agencies Final Guidance on Third-Party Risk Management

On Tuesday, June 6, 2023, Federal bank regulators issued final guidance outlining the guidelines and factors to consider when managing third-party relationships for financial institutions. The joint final guidance was issued by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the […]

Vendor Due Diligence Material

Every critical and high-risk vendor must have their fundamental business information gathered. Community financial institutions can use this information to assess if the vendor complies with any relevant local laws and regulations, as well as to spot any potential future performance problems. An essential element in the vendor risk management lifecycle is due diligence. In […]