Can Strunk’s ODP Manager Software Lighten Your Load?

Do you have employees now working from home? If you are using Strunk’s hosted ODP Manager software, this may allow you to adapt to changing work schedules or locations and easily give new users access. If you are a current ODP Manager client but do not have the hosted version, the upgrade is free!

Enjoy the benefits of a hosted solution. No more application software to support on your own network. No more worries about server and other support software becoming outdated. ODP Manager is upgraded monthly – requiring no support on your end – the upgrades are seamless and automatically available to your users. It doesn’t get any easier.

If you need a more efficient file import process, another huge benefit of the hosted solution is that you can import your extract file directly from your core processor while your users are not on premise. We encourage you to take advantage of ODP Manager’s Automatic Upload option – if your core can generate your extract file automatically then Strunk can help you set up the file import for a scheduled time each day. Then the data will already be imported and available when your users start their workday.

You may be unable to print letters every day or you may be trying to prioritize which letters can be printed at home versus ones that can wait to be printed from your normal branch location. Strunk can help you determine which letters are required and which letters may be omitted. We can also help you make any necessary letter content changes.

ODP Manager can save your reports within the software. Ask us to set up archived reports – then you can refer back to the daily reports as you have time available. Implementation of these strategies should help with the remote management of your ODP program.

 

Overdraft Programs During the COVID-19 Pandemic

Overdraft Privilege has been a staple for consumers for the past 27 years and paying items into overdraft status is better than returning them to the merchant or denying the consumer the ability to take home the groceries or prescription drugs.Given the recent circumstances our country is facing Strunk’s Overdraft Privilege program can help consumers and financial institutions get through these difficult times.

In ad hoc overdraft payment programs financial institutions decide to pay or not pay an overdrawn item and whether to charge a fee or not. These types of programs can be discriminatory and may lead to disparate treatment for some customers. In our formal overdraft privilege program those customers who are in the program want their items paid and they don’t mind paying you a fee. In essence you are saving them the return check charge from the merchant or the hassle and embarrassment of being denied at the point of sale.

Certainly there are times when waives or refunds are warranted. Make sure you have a documented policy that outlines the considerations to factor into the refund decision. Also, keep the authority to grant a refund as tight as possible – the more people with authority the greater chance of disparate treatment.

Strunk’s recommended Fresh Start Loan can be used as a tool to help consumers get back on their feet during financial hardships. If a consumer is unable to pay back an overdraft immediately we recommend allowing them to pay it back over four installments. The zero percent interest loan can be used at any time to help consumers pay back an overdraft over time rather than immediately like it is in most financial institutions.

Four installments could be weekly, monthly, bi-monthly or quarterly. Working with your customer to help them work out of a tight cash flow situation will strengthen the relationship and keep the negative information from affecting their credit score. More importantly, you will keep their checking account open under difficult times. Now more than ever, managing the day-to-day overdraft process as a line of business is a must and your customers will appreciate the service you are providing.

Setting the record straight on excessive use

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 consumers.

The first thing that we tell our clients is that overdraft privilege is a discretionary service, which primarily means that our clients are not obligated to pay any item.  With respect to both making the service available to consumers and taking it away from consumers, it is very important to be very consistent in applying your policy when managing your overdraft privilege program.  We tell our clients if they are not consistent with their program then desperate or discriminatory treatment could result from this action.

It is very important to understand that only the FDIC has guidance around ‘excessive use’ of overdraft privilege programs. If you are not regulated by the FDIC, then there are no specific rules regarding what a financial institution needs to do in case of excessive use.  FDIC regulated institutions need to notify a customer who overdraws their account on more than six occasions where a fee is charged in a rolling twelve-month period.  One thing to understand is there are no requirements to close an account or take any other specific action to accounts that use overdraft privilege on a regular basis.  Examiners or Auditors that push financial institutions to take action on these customers are really taking regulation into their own hands.

Strunk’s recommendation has always been to utilize the specifics that are outlined in our overdraft privilege service policy.  The only reasons for revocation of overdraft privilege are the reasons outlined in the service policy, otherwise coming up with arbitrary reasons to revoke certain customers access could be challenged.

Policy Management Made Easy

Banks are required to have each and every policy approved by the board of directors on an annual basis. Many financial institutions keep their policies in Word or PDF documents on the back credenza of the officer in charge of each area of the bank. Operational and compliance policies are in the operations area of the bank; lending policies are in the chief lending officer’s file cabinet and accounting policies on the cashier’s desk.

On average, banks have between 40-60 policies that are reviewed throughout the year by the bank’s board and any changes to the policies are updated after board approval. This process can be cumbersome and hectic for most community banks. It doesn’t have to be that way!

Strunk has put together a terrific solution for managing the annual review and policy approval process. Rather than maintaining separate folders of policies, why not have them in one place with access to those who need to read, make changes, or review them periodically? That is what Strunk’s Policy Manager Program does.

Keeping a log of changes for senior management, outside auditors, or the regulators is important. Making updates or changes to policies should be easy to do. Redlined copies of the policies go to the board for approval. Your board only wants to review changes made to policies, not the entire policy. Strunk’s solution does all of this and policies are put into chapters based on each functional area of the bank. You send us your policies; we do all of the work. Access to each policy is given based on user access code. Contact us for a quick demo of the cost effective, yet comprehensive Policy Manager solution.

Make ODP Manager Letters and Events Work for You!

Have you considered how you may customize ODP Manager for your institution?

Do your users need the ability to share information about ODP Manager accounts? ODP Manager allows users to create account comments and reminders. These events are available to all users and you can even add attachments! Overdue reminders are easily viewed each day when logging in.

Are there ODP related letters that you are generating manually? An Ad Hoc letter can be created for you to generate as needed – just enter the account number and the letter will pre-fill with the account information in ODP Manager. Once it is generated, it will be tracked and retained within ODP Manager just like your Collection and Custom letters.

Would you like the letter signature and contact information to change based on the account’s assigned branch? ODP Manager can do that for you!

Would you like your ODP letters to show your logos and footers instead of printing on letterhead? Would you like a user’s signature to print on your letters? If you provide your image files or text, they can be included in your ODP Manager letter templates.

Let ODP Manager help your users streamline account notation and letter generation by implementing these suggestions.

Opting in for Overdraft Protection

Banks and Credit Unions have been providing Overdraft Protection programs for many years but 10 years ago all debit card and ATM transactions that created an overdraft had to have consumer consent before the financial institution could pay the debit and charge a fee.

Prior to 2010, paper checks were nearly 50% of all debit transactions a bank would process and today less than 8% of all debits are paper. Consumers paying with a debit card or electronic transaction is a common practice and we are nearing the situation many predicted 30 years ago of a paperless society for banking transactions.

If consumers want to take home their prescriptions or groceries when paying with a debit card when there are insufficient funds in their account, a bank or credit union cannot automatically authorize the transaction. Beginning on July 1, 2010 a financial institution had to obtain opt-in for these transactions pursuant to Regulation E.

A financial institution can obtain opt-in via their website, in person, by mail, or over the phone. It is not required that a financial institution obtain a signature on the prescribed Federal Reserve’s A-9 form, nor do the forms have to be kept for any period of time. If a consumer opts-in, a confirmation of the opt-in must be sent to the consumer.

Opting-in is a great service for those customers who want flexibility in managing their account. Others may not see any benefit to opting-in. But it gives consumers complete choice on how they want their account handled when it comes to paying for things they need when they are short on funds.

Strunk at ABA’s Conference for Community Bankers

Strunk was proud to exhibit once again at the American Bankers Association’s Conference for Community Bankers February 9-11th. This event always proves to be one of our favorites, this year hosted at the Omni Orlando Resort at ChampionsGate. The event is a great way to reconnect with many customers and to build relationships with new bankers each year.

We welcomed the opportunity to show attendees the latest features offered by our Governance, Risk Management and Compliance (GRC) software. The solution now includes six GRC tools – Risk Assessor, Policy Manager, Controls Manager, Skills Manager, Issues Manager and Vendor Manager. We also had some great conversations regarding our state-of-the-art ODP Manager program and were able to visit with many long-time clients.

Strunk was excited to debut our new Vendor Manager application to the ABA membership. Vendor Manager provides an easy to follow standardized process to assess risk, gather due diligence materials, evaluate contracts and stores all vendor documentation in one convenient place. Vendor Manager keeps everything organized, is simple to use and of course, follows the latest FFIEC guidelines.

The most enjoyable part of the event just may have been our conference t-shirt station. Attendees were able to choose from one of 4 designs and watched while their customized shirt was made right before their eyes!

Congratulations to Paul McLaughlin of Litchfield Bancorp who was the winner of our TaylorMade Spider X Putter!

Thanks to all who stopped by, and to the ABA for once again putting on a great event. We are already looking forward to next year!

The Importance of Moving away from Spreadsheets for Vendor Management

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 organizations have adopted a vendor management process using spreadsheets – which lacks consistency, efficiency, clarity, effectiveness and oversight.

A software solution will help you move beyond spreadsheets and onto a centralized system that will streamline your process and clarify the procedure for everyone involved. Having an automated system will help you manage your vendors more efficiently. Examiners are looking for programs that have automated contract management and due diligence alerts when documents are nearing expirations and also comprehensive assessments, such as risk and controls assessments. An automated system will manage these processes more effectively and efficiently by creating a consistent workflow that a spreadsheet can’t produce. Additionally, a software solution is a more effective way to manage your vendors because it will reduce likeliness of user errors that spreadsheets can cause by keying mistakes or employees not using the correct spreadsheet because there could be multiple copies that are being saved.

With increasing regulations and demands concerning governance and compliance, companies can no longer risk using spreadsheets to manage third-party vendor polices and procedures. By using a centralized vendor management software system, organizations can simplify and standardize their process, effectively managing vendor risk and relationships, and ultimately saving time and money throughout the entire company.

Focus on Reg E Opt-in Now More Important Than Ever

It has never been more important to ensure that your financial institution has adequate coverage in regards to account holder Reg E opt-in. Reg E opt-in allows you to authorize ATM withdrawals and everyday debit card purchases, which may overdraw an account holder’s checking account, as long as they have provided their consent for you to do so.

Data recently released by a 2019 Federal Reserve Payments study shows that only 9% of all transactions in 2018 were from checks paid and 16% were via ACH. An overwhelming 42% of transactions were made via debit card. This decline in traditional transaction types, in favor of a debit card, means that it is extremely important to focus on the proper opt-in approach.

According to Part 205 of Electronic Fund Transfers (Regulation E), the financial institution must give “Reasonable opportunity to provide affirmative consent.”

A financial institution provides a consumer with a reasonable opportunity to provide affirmative consent when, among other things, it provides reasonable methods by which the consumer may affirmatively consent. A financial institution provides such reasonable methods, if—

  1. By mail. The institution provides a form for the consumer to fill out and mail to affirmatively consent to the service.
  2. By telephone. The institution provides a readily-available telephone line that consumers may call to provide affirmative consent.
  3. By electronic means. The institution provides an electronic means for the consumer to affirmatively consent. For example, the institution could provide a form that can be accessed and processed at its Web site, where the consumer may click on a checkbox to provide consent and confirm that choice by clicking on a button that affirms the consumer’s consent.
  4. In-person. The institution provides a form for the consumer to complete and present at a branch or office to affirmatively consent to the service.

By arming your team with the most effective procedures, you can be certain to achieve optimum opt-in for your organization. Strunk has a proven track record of achieving maximum results with financial institutions across the country. We help to more effectively reach your goals, all while remaining in compliance with applicable laws and regulations.

 

Does Your Overdraft Payment Program Have Exclusion Creep?

For the past 27 years Strunk has been the leading provider of formal overdraft payment programs to financial institutions across the country. Many of these programs were put in place in the early to mid 2000’s, well before Regulation E changed the overdraft landscape in 2010.

Some financial institutions have let their programs die and others have put them on the back shelf as fee income derived from the service has gone down. Others continue to wonder what they can do to revitalize their 10-20 year old program.

So, what has happened? In virtually all financial institutions, the number of consumers participating in the formal overdraft program has dropped significantly. For one reason or another, the account holder has been taken out of the formal overdraft payment program. Strunk calls this “Exclusion Creep”. Virtually all of our 1,800 clients had 90%+ participation when the program was implemented but many institutions have 65-75% of their accounts in the program today.

Managing this is paramount to providing a good service to all of your customers and to maximizing fee income. Take a look at your consumer checking accounts and see if they have an overdraft limit assigned to the account. If not, re-qualify them and put them back in the program. Consumers want the service and managing the overdraft program like a line of business benefits everyone.

Does your financial institution have Exclusion Creep?