Lately, there has been a lot of confusion around consumers who ‘abuse’ the overdraft privilege program from our clients. Our clients have asked us what they should do for their consumers who use the overdraft privilege program on a regular basis and what are the recommended compliance and regulatory practices they should follow for these […]
Over the past several years, regulators have targeted vendor management as one of their top regulatory concerns. With growing dependence on third parties for services, the need for effective vendor management programs has increased. While regulatory framework for vendor management has been in place for years, the detailed expectations and efficiency have been missing. Most […]
As the end of the year approaches, we have seen more and more clients loose potential additional fee income by waiving or refunding customer OD/NSF fees. This is often lost income potential that is unknown to the institution. Generally most systems are set up to charge fees after the pay/return decisions have been made, so […]
Understanding the increase dependence that financial institutions have on technology service providers, bank regulators have increased their efforts to require banks to appropriately handle third-party risk management. The Federal Deposit Insurance Corporation (FDIC) has identified gaps noted by some examiners regarding several technology service provider contracts that were inadequate under existing guidance. These contracts were […]
Companies may outsource an activity, but cannot outsource accountability. In today’s economic environment, almost every aspect of a company’s operations can be outsourced efficiently. As a result companies interact with vendors on a daily basis, opening themself up to additional risk. Vendor Risk is a type of Operational Risk associated with the potential risk that […]
Understanding the increasing dependence that financial institutions have on technology service providers, bank regulators have ramped up their efforts to require banks to appropriately handle third-party risk management. The Federal Deposit Insurance Corporation (FDIC) has identified gaps noted by some examiners regarding several technology service provider contracts that were inadequate under existing guidance. These contracts […]
Remember the old story about a farmer that discovered his goose was laying golden eggs? He got greedy and decided to kill the goose to get all the eggs at once, only to discover there was nothing inside. Well, this is a good analogy for overdraft privilege – your ODP program is the goose and […]
An independent certified public accountant has examined Strunk’s operations and found them to be in compliance with the AICPA’s Trust Service Principles. It was determined that Strunk meets the Security, Availability, Processing Integrity, Confidentiality, and Privacy criteria for SOC 2 established by the AICPA.
