What is a Fourth Party Vendor and Why Should I Care About Their Risk

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Fourth-party risk is rising to the top of most auditors and examiners list when it comes to evaluating financial institutions vendor management program.  Fourth parties are your vendor’s third parties and subcontractors.  These vendors you will not have a direct contract; however, your vendor does, and relies on these vendors to produce a product or service for them.  Most of the time these vendors will be visible in your vendor’s SOC reports and should also be easily identified by your vendor as those classified as critical in their own vendor management program.

Financial Institutions should care about fourth-party vendors risk, because they are subject to the same risk as your vendors, which puts you at the same risk without having the same oversight that you have over your own vendors. Financial institutions are ultimately responsible for the protection of their customers data, sometimes a fourth-party vendor can expose the financial institution to reputational, operational or cybersecurity risk.  All it takes is a single opening for a threat to compromise protected information.  Like any risk, there can be serious business implications, from fines to legal issues which can negatively affect a business if the fourth-party risk is unchecked.

The most effective way to manage fourth-party risk is to build a mature, comprehensive vendor risk management program.  If you have the right practices and processes in place, then incorporating fourth parties into those processes should feel manageable and mostly seamless.  Your vendor management program should help you identify your most critical vendors.  Once you do that you can ask them who their vendors are; what products and services do they provide to the vendor that cause them to be classified as critical to their operations; and what due diligence on the fourth-party vendor has your vendor perform on them.

Customize Your ODP Manager Letter Templates

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Templates for all your necessary Collection and Custom letters are included with Strunk’s hosted ODP Manager software. We’ve provided the letter content for you but there are customizable letter template options to allow your letter appearance to be consistent with other letters sent by your institution.

Do you have a standard letterhead that is used for your customer communications? ODP Manager can save your header and footer information so you can print your letters on plain paper instead of letterhead.

Do you typically sign your letters? ODP Manager allows the flexibility to store signatures for each of your ODP Manager users. No more signing letters – the signature can print with your letter! A signature can be used for all letters, or the signature can change based on the user generating the letters.

Do your customers contact a central location to discuss the ODP Program information or do they contact their local branch? With the hosted software, letters can include a single contact number, or the included phone number can change based on the account’s branch. ODP Manager can even change contact names based on the account’s branch.

Take advantage of hosted ODP Manager’s flexibility to create letter templates specific to your institution. Please contact Strunk Support at support@strunkaccess.com with any questions or for more details.

Is your Financial Institution Ready for Digital Lending?

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Digital banking has been around for about a decade as community banks and credit unions scrambled to offer consumers something big banks started in 2007. Mobile banking really started in Europe in the late 1990s and it took over ten years for it to become popular in the United States.

Mobile banking gives consumers 24/7 access to their deposit account. Most mobile apps allow for bill payments, remote deposits, fund transfers and some even allow person to person payments. Mobile apps have not provided any type of service on the lending side of the house until now.

The buy now pay over time solutions that many consumers are using started in Europe several years ago and in the past year they have become popular in the U.S. Just like mobile banking, the financial institutions here have lagged behind the rest of the world when it comes to digital technology solutions for consumers.

The Quilo mobile app provides instant access to small dollar (over $250) consumer loans that can be used at 1) POS or for online purchases; 2) to pay down or pay off credit card debt; or 3) to replenish a checking account for recent debit card transactions. The loans follow strict credit underwriting by each institution. Funding, collections and reporting is handled by the Quilo app.

Strunk has partnered with Quilo to provide a turn-key solution that will meet consumer demands by providing small dollar lending profitably. Quilo will substantially increase loans, net interest margin and interest income.

For a quick demo of Quilo contact Strunk at info@strunkaccess.com or 800.728.3116.

The Prospect of Eliminating Overdraft Fees

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Ally Bank has recently made headlines announcing that it would no longer charge its customers overdraft fees. Ally is a popular online bank that offers one type of checking account and overdraft fees only accounted for less than .07% of Ally’s revenue in 2020.  Ally Bank typically excludes consumers that use overdraft protection to begin with; of their 2.5 million banking clients, only about 1% have been subject to overdraft charges in the past.

When a financial institution decides to eliminate overdraft protection to their account holders, how does that really affect the consumer? First, if the account holder writes a check for more than they have in their checking account then that check gets declined (the check bounces) and sent back to the payee who tried to cash the check.  Once the check is returned, the account holder is charged an NSF fee and most likely charged a return fee from the payee or the merchant.  After a check is returned, the payee or merchant might try to re-deposit/re-present the check to see if the customer has the funds available.  If the account holder does not have the funds available then they are charged another fee.  Without overdraft protection these types of transactions can be very expensive because the consumer will have to pay an NSF fee, return fee and most likely re-presentment fee as well.  Also, the account holder will be inconvenienced because the check did not clear, meaning the payee has still not been paid.  Ultimately, the consumer will have to deal with the embarrassment of having their item returned.  Secondly, if an account holder doesn’t have overdraft protection on their account then that account holder is not allowed to have their debit card covered under an overdraft program.  Most consumers enjoy the convenience of having their debit card approved for a transaction that may overdraw their account rather than having those transactions declined.

After reviewing banks that are offering no overdraft fees accounts, Strunk has found that most of these banks are just setting up automatic transfer from another account or a line of credit to cover the overdraft items.  Also, if a bank is offering no overdraft fees there are some restrictions you may need to consider on the account.  Some of the restrictions to the account could be that the account doesn’t offer checks.  The bank may impose higher minimum balances or direct deposit requirements to reduce the occurrence of a transaction being declined, and if the account holder does not have the required daily balance or required monthly deposit amount then there is usually a monthly maintenance fee on the account. Strunk recommends that your organization consider all of these situations when evaluating an account type without overdraft protection.

Options to Display Your ODP Manager Information

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Strunk’s hosted ODP Manager software features customized letters, comprehensive reporting, and advanced history tracking. It helps you access your financial institution’s overdraft program information in a format that is flexible and easy-to-use.

After the daily extract file has been imported into ODP Manager, letters due and management reports are updated and ready to view. This gives your users the freedom to decide whether they would rather generate letters first or review daily reports first.

Monitoring the percent of accounts with an overdraft limit and the percent of accounts opted in for Regulation E is important for maintaining or improving your ODP program’s performance. Strunk puts these important metrics on your ODP Manager dashboard. The Utilization Analysis and the Opt-In Impact reports also include more detailed information by branch and by product. Daily reports are accessible for the most recent seven import dates. If you choose to use the Report Archive feature in ODP Manager, you are able to have copies of your reports automatically saved in the ODP Manager software after each import is complete.

How are you able to view the data in ODP Manager at a more granular level? Filters on Reports and Account Inquiry allow you to limit your results to accounts that share specified criteria. You can search events to identify activity during a certain timeframe or to generate a list of specific letters sent or events tracked in ODP Manager. You can navigate to individual account details from your letter generation screens, from a report, or you can directly search for open or historical account data in Account Inquiry.

Hosted ODP Manager allows you to take advantage of multiple methods to view the data imported from your extract file and the information tracked in the ODP Manager software. Please contact Strunk Support at support@strunkaccess.com with any questions or for more details.

Banks Must Meet Consumer Demand. Don’t Let Fintechs Steal Away your Account Holders!

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Consumer purchasing behavior changed in 2020 with the pandemic and retail shops closed in an attempt to stop the spread of the virus. Credit card transactions were up in 2020 compared to 2019 but credit card receivables were down substantially during the same time period. What happened?

People of all ages have aligned themselves with the buy now pay over time business that has finally come to the United States. Many younger consumers like the idea of buying a major item and paying it off rather than putting the purchase on an evergreen credit card that never seems to go away. Now people of all ages are using the service and the proliferation of this business is something bankers need to pay attention to.

In 2010 Square began offering bank’s small businesses a solution to run their payments solution without a banking relationship. Mobile card readers allow small business to receive payments for goods purchased. Why didn’t banks offer this to their customers? Why did a Fintech steal this business from banks?

Just six years ago a company called Quicken Loans started a mobile app for mortgage loans called Rocket Mortgage. They were the first Fintech to underwrite, fund and close mortgage loans in all 50 states. Now they are the largest home lender in the US. Why did a Fintech take this business away from banks?

Now companies like Venmo, PayPal, Sezzle, Affirm, Klarna, SoFi, Open Pay and Quad Pay are once again taking customers away from banks. They offer buy now pay over time for purchases made through merchants. Your bank’s customers are making their monthly payments from their checking account at your bank. Now, many of these companies are offering high interest checking accounts as well. Why did the Fintechs take this business away from banks?

Strunk has a turn-key technology solution that will meet customer demands by providing small dollar lending profitably. For a quick demo of Quilo, contact Strunk at info@strunkaccess.com or 800.728.3116.

Risk Management Done Right

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Strunk is best known for our fee income improvement programs, including Overdraft Privilege, Rewards Checking and Value Checking. Most recently we have expanded our offering to assisting community financial institutions with their risk management and compliance processes using our software.

Strunk offers six comprehensive, easy-to-use and affordable compliance management tools:

Risk Assessor helps you prepare comprehensive risk assessments consistent with regulatory or other requirements, in days, not weeks.

Policy Manager organizes all your policies into a single database, mapped to the relevant standards and control procedures.

Controls Manager schedules tests of policy compliance and tracks test results.

Vendor Manager is a specialized tool for managing vendor risk that standardizes risk assessment methodology and organizes all vendor related documentation.

Issues Manager is a centralized database for tracking all compliance issues and incidents across your entire organization.

Skills Manager provides online testing and training to ensure employees are knowledgeable about your policies.

According to Dan Roderick, CEO, “Strunk’s Risk Manager solution brings efficiency to the process and allows our clients to focus on their highest areas of risk. The solution is comprehensive but simple to use, which is something I wish I’d had access to in my days as a banker.”

All our tools are securely and reliably hosted with Amazon AWS, making them available on a variety of devices from anywhere. Risk Manager facilitates remote work and will greatly enhance your internal control and risk management processes and save time – all for one low annual fee.

If you are paying another vendor an annual fee for any one of these tools today, invest just 30 minutes to review our solution suite. We can add valuable services – and may be able to SAVE you money as well!

3 Common Mistakes in a Vendor Management Program

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  1. Not completing a risk assessment on all vendors.

Some companies may decide not to do a risk assessment on a vendor because of the contract value or the type of work that the vendor is performing for the business.  Each vendor that provides a product or service for your business should have a risk assessment completed.  By performing a risk assessment on all vendors, it allows your business to better understand the risks that exist when they use a vendors’ products or services.  Conducting a risk assessment for all vendors is particularly important when a vendor handles a critical business function, accesses sanative customer data, and/or interacts with customers.  It will also help you categorizes your vendors by risk level.  By categorizing your vendors by risk level, it will allow the business more time to focus on those vendors that have a higher risk.

  1. Not conducting vendor reviews.

Vendor reviews help manage your vendor’s performance.  A quality vendor review assesses how the vendor is performing against Service Level Agreements (SLA) and Key Performance Indicators (KPI) that are established in the contract.  It should also show non-contractual performance issues, such as incidents that aren’t measured by a service level.  Understanding the vendors situation, performance and how they handle third parties is crucial for the businesses on-going monitor of their vendors.  Vendor reviews are perfect way to partner with the vendor for a successful relationship and to hold the vendor accountable for their performance.

  1. Storing vendors due diligence material in different places.

Vendors due diligence material assist the business with selecting a vendor, contracting, and ongoing monitoring.  This process can be very difficult for businesses that don’t have a centralized repository to store their vendor documents.  Having a centralized repository for your vendors documents will help streamline and organize your vendor manager program.  With this process in place, it makes it easy for another employee to find the documents that are needed, and the business can also set reminders on when the document needs to be updated.

Protect your Customers from FinTechs?

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For the past 40 years community financial institutions (CFIs) have shied away from making small dollar installment loans to consumers due to the unprofitable nature of the loans. Underwriting costs, funding, collections, and managing the loans generally exceed the interest received from the customer. Banking technology has been slow to adapt to the wants and needs of consumers. Now, FinTech companies are taking the business away from our industry.

Making auto loans was something most financial institutions did until the car manufacturers started offering 0% interest loans. Indirect lending took off as well with CFIs working with the local car dealer to finance auto purchases. That too has slowed as competition from credit unions and captives have offered lower rates to consumers. What can a CFI do with all of the low cost deposits they have received since March 2020?

Quilo is a Strunk partner and the solution provides instant access to small dollar installment loans to consumers through a smart phone app. The white labeled Quilo app underwrites, approves, disperses funds, collects and reports the loans to the financial institution. Your CFI funds each loan and the underwriting criteria are completely controlled by each financial institution. All consumer disclosures are handled through the app but they are the same as you use today.

There is a unique opportunity to get back into the installment lending business as the buy now pay over time business proliferates. The high yield low touch Quilo platform is a turnkey solution that requires very little time or money on your CFI’s part. Let’s stop the FinTechs from taking our loan and deposit customers.

For a quick 45 minute demo of Quilo, contact Strunk at info@strunkaccess.com.

Repayment Plan Tracking in ODP Manager

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ODP Manager requires you to update the software daily with the updated deposit information from your core processor but can it also help you manage information not included in your daily extract file?

Included in ODP Manager, you can choose to track your Fresh Start Loan repayment schedules within the hosted software. After completing your Fresh Start Repayment Plan assessment and approval process, you can enter the repayment schedule information directly in ODP Manager. The schedule can be used to populate your Fresh Start Loan agreement and will streamline generating the document for your customer to sign.

The repayment plan will automatically leverage Strunk’s Reminder feature to create reminders when each payment is due. This will help your Strunk software users remember to check your core system to see if the payments have been made as agreed. Once you’ve verified the payment receipt and entered the data, ODP Manager will show the payments made and the outstanding balance on the repayment plan.

Each repayment plan can be viewed individually for each account. All repayment schedules are also summarized in a list that can be exported to PDF or Excel for reporting purposes.

By using the repayment plan tracking feature, you may be able to make managing Fresh Start Loan payments easier and facilitate reporting. Please contact Strunk Support at support@strunkaccess.com with any questions or to find out more.

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.