Regulation E and ODP Manager

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Consumers are required to opt in to include their ATM and everyday debit card transactions in Overdraft Privilege. Customers should be given the ODP Policy and A-9 Consent Form to opt in for Reg E at account opening but they may also opt in later. The four options to opt in for the ATM and everyday debit card coverage are: in person at a branch, over the phone, by mail, or electronically. Businesses are not required to opt in to have their ATM and everyday debit card transactions covered by Reg E.

For financial institutions that provide an account’s Reg E Opt In flag in the extract file, ODP Manager can determine if a consumer account has already opted in or has not yet responded with a Reg E election. If a customer has already opted in for Reg E coverage, their Welcome and Reinstatement letters will remind them that their Overdraft Privilege service includes coverage of ATM and everyday debit card transactions.  When a Welcome, Reinstatement, or Followup letter is mailed to accounts that have not yet opted in, these letters include the A-9 Consent Form to Overdraft Services and the information about opting in by mail, in person or over the phone, or electronically. By allowing customers the Reg E opt-in information when overdraft limits are assigned, when overdraft limits are reinstated, or annually in the Followup letter, ODP Manager may allow customers to have more opportunities to opt in for Reg E.

ODP Manager can also allow customers to submit their Reg E Opt-in election electronically. Strunk can create an online form that mirrors an institution’s A-9 form. This form would then be linked directly from an institution’s website. Email confirmations are generated when forms are submitted. The submissions are tracked in ODP Manager so that users can generate a list of accounts that need an updated Reg E election.

If you have any questions about Regulation E and ODP Manager, please contact Strunk Support at support@strunkaccess.com for more details.

Time to Revitalize your Overdraft Payment Process

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Recently the CFPB backed off guidance for overdraft payment programs and now is the time to consider revitalizing your bank’s overdraft payment services. While the regulators scared off some banks from offering a formal overdraft program, many banks and consumers have benefited from them for over 30 years.

Consumers create overdrafts…banks do not. Banks are faced with decisions each morning to either pay a customer’s non sufficient fund item or return it to the merchant. Providing a consistent method with these decisions eliminates problems and streamlines the process. Strunk’s program covers all aspects of offering a compliant overdraft privilege service to consumers and small businesses.

Beginning in 2010, debit card transactions that would overdraw an account could not be authorized at point of sale unless the consumer “opted in” and “signed-off” for this service. This was a great idea that came from the Federal Reserve. So, how do formal overdraft programs benefit consumers?

  • Allows consumers to decide how they want their bank account handled when it comes to overdrafts
  • Reduces returned check charges from merchants
  • Allows consumers to take home the groceries or prescription drugs when otherwise their debit card transaction would be denied
  • Keeps a bank from discriminating on daily pay and don’t pay decisions
  • Keeps a bank for discriminating on waives and refunds

Contact Strunk at 800-728-3116 or email at info@strunkaccess.com to learn more about revitalizing your overdraft payment process at your bank.

 

How can Strunk’s Vendor Manager software support your organization’s Third-Party Risk Management process?

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Several key elements must be considered in the Third-Party Risk Management process for financial institutions. Banking regulators issued a joint statement highlighting the risks faced by financial institutions when partnering with third parties for bank deposit products and services, along with examples of effective risk management practices to help mitigate these risks.

Strunk’s Vendor Manager software aids in minimizing risks by providing a framework to collect vital data and processes. Third-party risk management is an ongoing process that begins with due diligence prior to signing a contract and continues with regular monitoring throughout the partnership. Strunk’s Vendor Manager software facilitates comprehensive risk assessments and evaluates vendor controls for your financial institution. Furthermore, it offers a storage solution for due diligence documents related to potential third parties before you engage with them. Strunk’s vendor risk assessments are standardized evaluations designed to meet regulatory standards and align with your financial institution’s risk appetite. This assessment categorizes and ranks each vendor based on their potential risk.

After negotiating a contract, Strunk’s software offers a secure location to store your contract and highlight any discrepancies, ensuring it thoroughly outlines the responsibilities and obligations of both the financial institution and the vendor. Furthermore, it enables you to monitor key dates and generate insightful reports for the financial institution’s leadership and management.

Ongoing evaluation tracks the vendor’s performance and risks during the entire relationship lifecycle. Strunk’s Vendor Manager software features a customizable monitoring section, acting as an efficient tool for assessing, overseeing, and controlling third-party risks.

Financial institutions need software to maintain detailed records associated with risk and to produce reports on third-party risk management activities for stakeholders. Strunk’s Vendor Manager software can assist you in meeting all your Third-Party Risk Management program goals. Click here to learn more or contact Strunk at info@strunkaccess.com.

Overdraft Privilege Continues to be an Important product for Consumers

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With the ongoing negative perception and strict regulations surrounding overdraft privilege, financial institutions find it increasingly challenging to offer this service. Most adults in the U.S. consider overdraft privilege a valuable resource at a reasonable price, highlighting the significant disconnect between regulators and public sentiment.

Overdraft privileges help consumers avoid declined transactions, which can lead to late payment fees and non-sufficient funds (NSF) charges. Consumers feel it is essential to have overdraft privileges to ensure that large payments, such as mortgages or rent, are covered and paid on time if these payments overdraft their accounts. Generally, overdraft privilege is more affordable than some short-term credit alternatives, like payday loans. This is why most consumers have not seriously considered giving up their overdraft privilege. While some consumers with a buffer amount in their checking accounts may not need overdraft privilege, for most Americans, it is necessary to prevent essential transactions from being declined.

When surveyed, banks have found that consumers appreciate that banks covered payments that would have otherwise been declined. Consumers have an easier time checking their account balances than ever before. With access to their accounts via websites or mobile apps, many Americans can monitor their account balances to avoid overdrawing their accounts and incurring fees.

For decades, Strunk has supported financial institutions in delivering a convenient overdraft privilege to their clients while enhancing fee income and ensuring full compliance. Our consulting services for overdraft privilege, combined with top-notch software, can help your institution’s program thrive. Given the increasing regulatory scrutiny, our compliance guarantee is becoming even more crucial. As regulators focus on returned checks and re-presentment, our Overdraft Privilege (ODP) program provides excellent service to customers by covering item costs instead of returning them.

Click here for more information or to contact Strunk for a demonstration.

ODP Manager Comments and Reminders

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Hosted ODP Manager allows users the option to create comments or reminders as needed. If institutions do not already have a robust method of tracking notes, they can choose to use this useful feature. The comments and reminders are created for the individual account. They are retained in the individual account view and are printed with the Account Summary PDF as well.

After speaking to the customer or reviewing the account, users can add notes that can be viewed by all ODP Manager users. Comments can be used to document information. Reminders can be used to identify items that need follow up as of a certain due date. Attachments can be added in comments or reminders as needed.

Comments or reminders are created by clicking the Calendar or Speech icons when viewing the accounts listed in Account Inquiry. The Calendar and Speech icons can also be used in the letter generation screens, or on the Overdraft Aging, New Accounts, Status Tracking, Fresh Start Tracking, or Heavy OD Users Reports. When viewing an individual account’s reminders or comments, the Add Reminder or Add Comment buttons can be clicked.

Overdue reminders are displayed in the Events section which users can access by clicking Events in the purple bar in ODP Manager. Upcoming reminders can also be displayed. Once reminders are completed, they can be marked as closed.

If you have any questions about using comments or reminders in hosted ODP Manager, please contact Strunk Support at support@strunkaccess.com for more details.

Using ODP Manager to Review Your Overdraft Privilege Program Information

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Strunk’s hosted ODP Manager software is updated daily with information contained in an extract file generated from your core system. After the daily import, users can generate letters, review management reports, and access additional information to effectively manage a compliant ODP program.

Percent of accounts with an assigned overdraft limit and percent of accounts opted in for Regulation E are important metrics to monitor for the success of an ODP Program. This importance is highlighted on the Dashboard which is displayed after each ODP Manager login. Trends in the Percent with Limit and Percent Opt In are shown over several months. Monthly benchmarks for the Percent with Limit and Percent Opt In are compared to other Strunk clients by the 25th, 50th, and 75TH percentiles. Overdraft Fee and Overdraft Limits are also benchmarked against other Strunk client percentiles. The Utilization Analysis report and the Opt-In Impact report allow users to further review the percentages summarized by branch and by deposit product.

On reports that include account-level details, users can apply filters or select groups to further examine data. Once the filters are applied, the filtered results can be exported to PDF or Excel for additional review or discussion. Reports that show account details include Overdraft Aging, New Accounts, ODP Status Tracking, Fresh Start Tracking, and ODP Heavy Users.

In the Account Inquiry area in ODP Manager, users can apply column filters and groups. If users need to create a list of accounts meeting certain criteria, Account Inquiry gives them the flexibility to build the list and export it to Excel. This flexibility allows users to access all the data included and mapped from the daily import file.

ODP Manager also allows users the ability to search for specific events that occur during a date range. This can help users compile a list of letters sent, OD limits assigned or removed, or Reg E opt ins or opt outs.

If you have any questions about ways to view or export the data in hosted ODP Manager, please contact Strunk Support at support@strunkaccess.com for more details.

How to track responsibility for each vendor

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Financial institutions are increasingly outsourcing various business functions. Given the growing regulatory and compliance landscape, maintaining an efficient vendor management program is essential for any financial institution engaged in outsourcing risk. Having numerous vendors in your operations can complicate your vendor management program, especially if your financial institution is unclear about who is responsible for each vendor. In a vendor management program, the individual accountable for each vendor is often referred to as a ‘Vendor Owner.’ This person works within your financial institution to manage the daily relationship with the vendor, encompassing communication, contract oversight, performance monitoring, risk assessment, and resolution of issues. Essentially, they take ownership of the vendor relationship to ensure it meets the company’s needs.

The vendor owner is often a representative from the business unit that predominantly uses the vendor’s services. This person has extensive knowledge of the necessary product or service and is well-equipped to manage performance effectively. While this isn’t universally true, most financial institutions typically identify their vendor owners this way. In Strunk’s Vendor Manager software, your financial team can designate a vendor owner for each vendor, as well as assign responsibility for other activities such as contract management, risk assessment, and performance monitoring. An effective vendor management program must assign responsibilities and track them efficiently, which Strunk’s Vendor Manager software facilitates. It also provides reporting features to ensure tasks are completed on time and not overdue. Your financial institution can also categorize vendors in Strunk’s Vendor Manager software by defining vendor types, ensuring that each business unit understands which vendors they are responsible for. You can establish your own naming system in this customizable field. Identifying the business unit of your vendors and determining the vendor owner for each will enhance the organization and efficiency of your vendor management program.

 

Save Reports Automatically After Each Import

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The hosted ODP Manager software includes a comprehensive suite of standard reports. These reports should be reviewed periodically to assist with Overdraft Privilege program management and maintenance. These reports are updated after the daily extract file is imported into ODP Manager. Reports can be viewed in the browser or can be exported to a PDF or Excel file.

In addition to allowing users to review reports for the last seven as of dates in the browser, ODP Manager also offers a Report Archive feature. This allows past reports to be automatically retained so that they are available for future review, analysis, or comparison as needed.

Institutions can select which reports they would like to archive. After each import succeeds, the selected reports are saved as a PDF and stored within the ODP Manager software. The reports can be retrieved from the Archived Reports section in Reports and are organized by as of date. If users would prefer to download the reports to store on a network drive, the Archive feature can be configured to allow a Download Report Archive link instead.

If you have any questions about setting up or using the Report Archive feature in hosted ODP Manager, please contact Strunk Support at support@strunkaccess.com for more details.

The importance of ongoing monitoring of vendor relationships

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A crucial aspect of the Third-Party Relationship Life Cycle that is often overlooked is ongoing monitoring. Regularly monitoring vendors is vital for managing external risks and making sure that third parties adhere to compliance and performance standards throughout the duration of the relationship. The frequency of monitoring your vendor management program depends on various factors, such as the type of business relationship, vendor risk rating, vendor performance, and regulatory obligations.

To effectively monitor your vendors, begin with a risk assessment to evaluate the inherent risks they pose when introduced to your operations. This assessment will pinpoint areas that need careful oversight and establish how often you should conduct reviews, depending on the vendor’s associated risk levels. Next, define your monitoring criteria according to the vendor’s risk level. Establish thresholds and alert mechanisms within your monitoring system to identify any deviations from these criteria, enabling you to respond quickly to potential issues.

When establishing a monitoring process, choosing the appropriate third-party monitoring solution is crucial for supporting continuous oversight. Strunk’s Vendor
Manager software enables you to tailor your ongoing monitoring categories according to risk levels, automating the entire process. This improves efficiency and minimizes missed opportunities. Strunk’s software also helps track deviations and gives feedback on the vendor’s performance.

Ongoing monitoring is crucial for managing vendor risks, ensuring that vendors fulfill their contractual obligations, and adhering to regulatory standards. An effective vendor monitoring process enhances your overall vendor management program. Additionally, it serves as one of your most valuable tools to address minor issues before they escalate into major ones. Click here for more information.

Tracking Vendor Due Diligence Material

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How does your financial institution manage the tracking of vendors’ due diligence materials? Is there a centralized repository for these documents, or are they merely stored in folders on your computer? It’s important to note that Strunk’s Vendor Manager software offers a hosted solution designed to help financial institutions consolidate vendor due diligence materials into a single, central location.

Vendor due diligence materials include essential information about a vendor’s corporate history, financial status, legal structure, compliance record, operational capabilities, and potential risks of the partnership. A centralized repository for these materials removes the need to consult multiple sources, ensuring the information remains accurate, up-to-date, and easily accessible.

Key benefits of having a centralized repository:

  • Enhancing data accuracy and consistency: By keeping all due diligence documents in one location, the risk of conflicting or outdated information is reduced, ensuring that everyone utilizes the most reliable details for each vendor. This approach allows departments involved in vendor selection to share information effortlessly and collaborate on materials, ensuring everything stays current.
  • Streamlined review process: With all due diligence materials in one accessible location, reviewing vendor information is more straightforward, saving time and effort. This arrangement also simplifies the provision of necessary documentation during audits for your vendor management program.

Strunk’s Vendor Manager software establishes a centralized repository for your financial institution’s due diligence materials, granting swift access to all pertinent vendor information and significantly speeding up the decision-making process. Check out our site to learn more: https://strunkaccess.com/compliance-software/#vendors.

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.