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.

 

Using and Customizing Account Inquiry

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The hosted ODP Manager software allows users to view information about accounts that have been imported into ODP Manager. This information can be viewed as a list of multiple accounts or the account details for a single account can be selected. Account Inquiry is organized to allow users to select which data columns are displayed by choosing a View. Users can also select Groups to display accounts that meet certain criteria, or they can apply individual filters to display only the desired results. Once the list of accounts has been created, the data can be exported to Excel. This information can be used in addition to ODP Manager’s standard reporting and may be an alternative to creating customized reports.

Users are able to view the details in Account Inquiry for a single open or closed account. In order to manage the account or to address inquiries, users can use Account Inquiry to review basic ODP Information, contact details, or event history. If Fresh Start Repayment Plans, Charge-off Items, or Reg E Opt-In or Opt-Out information has been created or attached to the account, they can be accessed at the individual account level. Comments and Reminders can also be viewed. The individual account information can be aggregated and viewed as a PDF as well.

When viewing lists of accounts, institutions have two available options to customize Account Inquiry. The default Group assigned when users click Account Inquiry is Open Accounts. This will display all accounts that were included in the most recent file imported. The amount of time it will take for the results to load and display will vary depending on the number of accounts included. If an institution would prefer a different Group to load initially, Strunk can designate a different default Group. Also, Strunk can update the Account Inquiry behavior so that accounts do not show in the list until additional column filters have been entered. This may be useful for institutions with larger numbers of Open Accounts that are primarily searching for specific account numbers in Account Inquiry most frequently.

If you have any questions about using or customizing Account Inquiry, please contact Strunk Support at support@strunkaccess.com for more details.

Utilize the power of integration with Strunk’s Pricing Manager

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Strunk’s Pricing Manager is a full featured loan and deposit pricing solution and relationship profitability tool. It provides the ability to model pricing scenarios on individual loans, understand the pricing power deposits bring to the table and develop scenarios that work for both the borrower and the bank. The relationship profitability feature provides the ability to understand the total value of the customer to determine if that should be factored into pricing decisions. Finally, there are rate sheet tools for both consumer loans and deposits that help the bank build strategies to improve profitability. This approach is proven to increase bank net interest income by the equivalent of 25-50 basis points.

There is no question that taking the entire relationship into account when making new pricing decisions is extremely important. Strunk’s Pricing Manager integration feature automates this process and allows clients to import their entire loan & deposit portfolio directly from any core system. The process relies on a data extract file which is customized and configured for each client and then updated in accordance with a defined schedule.

Integration allows clients to make use of Strunk’s profitability analysis feature to identify areas where the bank may not be meeting target profitability objectives. Loans are grouped by type and then statistics such as number of loans, total balance, average yield, average life, and average ROE are captured. The analysis functionality also tracks the number of loan originations by type per month.
For more information on Pricing Manager or to have integration configured for your bank, please contact Strunk at info@strunkaccess.com or visit https://strunkaccess.com/pricing-manager/.

Banks Can Increase Customer Satisfaction & Fee Income at the Same Time

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Strunk’s Secure checking strategy has been around since 2011 and it will enhance customer loyalty while increasing fee income at the same time. Notably, the banking industry has lost nearly $20B in service charge income over the past 15 years and it has affected banks across the country regardless of size. Free Checking was offered by most every bank between 1990 and 2020 but now fewer banks give anything away for free.

Secure checking is easy to implement and it provides financial and lifestyle benefits to consumer accounts for a small monthly fee. Many times a bank’s customers are paying for these services elsewhere for substantially more than what the bank can offer them for. Consumers are willing to pay for value. Secure checking offers tremendous value.

Recently, banks have received a reprieve from the overzealous industry watchdogs but our industry is changing and consumer habits are changing. Tele-health services, roadside assistance, cell phone protection, Identity theft protection, and access to credit bureau and credit scores are examples of services a bank can provide at a fraction of the cost a consumer would pay individually.

Over 1,200 banks offer the Secure checking account to their offerings while maintaining free checking. You can expect income to go up by at least $50 per checking account per year. The program is easy to implement and easy to manage.

Contact Strunk at 800-728-3116 or email at info@strunkaccess.com to learn more about fee income programs offered by Strunk.

Options for ODP Manager Access

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Institutions should regularly review ODP Manager accounts to remove accounts that no longer need access to ODP Manager, whether because their roles have changed, or because they are no longer employees. Also, the existing roles assigned to users can be reviewed to confirm that they are still appropriate. ODP Manager includes four different roles that control access to the different features in the ODP Manager software.

ODP User rights should be assigned to users who will need to access all software features but will not need to make administrative software setup changes. If a user is assigned the ODP Admin role, they will be able to perform all the functions performed by ODP Users, and are also able to add and change users, revert imported files, and make or request software setup updates. For users that do not need to generate letters or import the extract file, ODP Report User rights will allow them to access ODP Manager Reports and Account Inquiry.

If an institution would prefer to separate User Administration from other ODP Admin functions, users can be assigned User Admin rights if they need to add or change ODP Manager users. Users that need to be able to revert imported files or make and request other software setup changes should be assigned ODP Manager rights.

When users no longer need to access ODP Manager, there are two ways for ODP Admins or User Admins to remove access. If the user is no longer employed by the financial institution, the user status can be updated to Former Employee and no rights will need to be removed. If the user is still an employee but no longer needs the ODP Manager access, the assigned ODP Admin, ODP Manager, ODP User, ODP Report User, or User Admin role can be removed.

If you have any questions about User Administration and Roles in hosted ODP Manager, please contact Strunk Support at support@strunkaccess.com for more details.

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.

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.