2023 Potential Focus

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In 2023, what will regulators and auditors focus their attention on the most? How can we get ready for a change in any law or regulations? How can Strunk’s software better prepare you for your audits and examines.

To determine the top regulatory hot button problems for 2023, Strunk examined supervisory priorities, enforcement trends, rulemaking agendas, speeches, blogs, and more. Below is the list of the items that seems to be focused the most on is 2023.

  • Loan origination and servicing: The CFPB expects every regulated entity under its supervision and enforcement authority to have an effective compliance management system adapted to its business strategy and operations. Examiners should also use the compliance management system review procedures, to conduct review and testing of components of the supervised entity’s compliance management systems which is part of the 2023 Supervisory Highlights Junk Fees Special Edition from the CFPB.
  • Credit Reporting: Inaccurate information on credit reports is the most frequent complaint that the CFPB receives. The CFPB refers complaints to your regulator agency even if they do not regulate you in their 2022 Fall Supervisory Highlights. Congress has issues of its own. Make sure your financial institution train workers, test credit reporting systems, and update rules and procedures that deal with the accuracy of information reported. Financial Institutions should immediately look into and resolve customer complaints.
  • Lending practices & fair lending: Fair lending is expected to remain one of the major compliance issues, if not the main one. In its most recent annual report to Congress on fair lending, the Consumer Financial Protection Bureau (CFPB) highlighted in their 2022 Fall Supervisory Highlights, its efforts to oversee activities related to “mortgage origination and pricing, small business lending, student loan origination work, policies and procedures regarding geographic and other exclusions in underwriting, and on the use of artificial intelligence (AI) and machine learning models.” The agency has a solid track record of carrying out its obligations. There is no reason to believe that this will change in 2023 given the bureau’s track record of following through on its commitments.
  • UDAAP focus on fees: A CFPB press release and information request from January 2022 helped popularize the phrase “junk fees” in the banking sector. The definition of a “junk” fee was not clear because the agency included services for concerts and hotel resorts with other fees that banks typically charge. However, the bureau explicitly mentioned overdraft, NSF, and late fees for credit cards in their press release. The bureau declared that in order to “reduce these kinds of junk fees,” it will “craft rules, issue industry guidance, and focus supervision and enforcement resources to accomplish this objective.”, which is stated in the 2023 Supervisory Highlights Junk Fees Special Edition.
  • Deposit accounts: Ensure that you are abiding by both local and federal laws and educate your workers on policies and procedures. Making sure that each consumers gets full details regarding their accounts and understands it. This has been covered in several CFPB and FDIC reports around UDAAP.
  • Vendor Management: Regulators are still very interested in your relationships with vendors, service providers, and fintech partners, particularly those who assist you in providing Banking as a Service. Your financial institution will be held accountable if a vendor violated consumer protection rules or caused a breach involving your data. Based on CFPB Consumer Financial Protection Circular 2022.
  • BSA/AML/OFAC: Regulators have gone after BSA officers and management with individual fines per BankersOnline.com BSA/AML Civil Money Penalties. Worldwide instability creates new sanctions. Financial Institutions must implement rules, including beneficial ownership rules for the next few years.
  • AI, algorithms and big data: It’s obvious that we’re only at the starting of sorting this all out because this subject has recently grown quite popular with the agencies. There are many facets of this problem to investigate, but one of the buzzwords is “digital redlining,” which refers to a form of discrimination where lenders limit credit availability or give credit on unfair terms based on applicants’ digital footprints. These new technologies are usually used by banks for marketing, fraud detection, and credit standards. Director Chopra’s comments focused on the use of AI in lending decisions. He stated that the CFPB will be “watching for digital relining,” citing what he called “algorithmic bias” and the need for investigation of whether “discriminatory black box models are undermining the goal” of equal opportunity.

Strunk offers a variety of software solutions to assist financial institutions with their Enterprise Risk Management. Strunk’s Risk Manager, Policy Manager and Vendor Manager solution will help financial institutions be better prepared for their audits and examines, covering most of the hot topics for 2023. Also, Strunk’s overdraft privilege programs assist financial institutions grow their bottom line while also making sure they are fully compliance with regulatory issues.

 

Strunk at the ICBA’s Live 2023

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The Independent Community Bankers Association held this year’s ICBA LIVE event all the way out in Honolulu, Hawaii from March 12-16 at the Hilton Hawaiian Village. In addition to the beautiful location, attendees enjoyed visiting with vendors in the Marketplace, various Learning Labs and sessions with ThinkTECH presentations.

Strunk was pleased to meet with so many bankers, discussing necessary solutions for community banks. Strunk was thrilled to debut their newest solution, Pricing Manager. Pricing Manager is a full-featured loan and deposit pricing solution that will provide banks with the ability to set loan and deposit pricing consistently and profitably. Commercial loans can be priced consistently by every lender – creating options for customers that all achieve the bank’s profitability targets. Additionally, rate sheets for consumer loans, residential mortgage loans, and deposits can easily be created that are also based on established profit objectives. Not only will Pricing Manager drive consistent achievement of profitability targets – it will also help you win more quality deals!

Strunk’s goal is to continually provide value-added SaaS solutions that help community banks increase profitability, while controlling operating expense. In addition to their latest offering, Strunk highlighted their overdraft service and best-in-class governance, risk and compliance solution, Risk Manager.

For more information on Pricing Manager or Strunk’s other solutions, visit https://strunkaccess.com/ or contact Strunk at info@strunkaccess.com.

Communicating Alternatives to Overdraft Privilege

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Financial institutions are expected to monitor excessive consumer Overdraft Privilege activity in order to advise customers of alternative options to cover overdrafts.

FDIC regulated institutions are expected to give customers who overdraw their accounts on more than six occasions where a fee is charged in a rolling twelve-month period a reasonable opportunity to choose a less costly alternative and decide whether to continue with fee-based overdraft coverage. Strunk also recommends that institutions not regulated by the FDIC also communicate available alternatives to ODP on an annual basis to accounts with insufficient funds items.

The hosted ODP Manager software includes a letter template which can be used to notify customers of the available alternatives to Overdraft Privilege. The alternatives, overdraft protection credit lines and/or overdraft protection transfers from a linked account, are both described in the letter including information about associated charges or fees and whether an application or request is needed to initiate coverage.

This Excessive Use Notification letter can be generated in ODP Manager based on criteria included in the daily extract file or as needed as an Ad Hoc letter. If the file imported daily into ODP Manager includes data from the core that indicates when an account has qualified for the letter by exceeding the threshold, the hosted software can automatically show when a letter is due. If the data is not available in the extract file, letters can be generated for each account identified using an existing core report or other method.

Whether the letter is generated based on criteria or as an Ad Hoc letter, the letter will be tracked for each account and retained within the hosted ODP Manager software.

Please contact Strunk Support at support@strunkaccess.com with any questions or to find out more details about ODP Manager’s Excessive Use Notification Letter.

Strunk Response to Recent Overdraft Headlines

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It is no secret that overdrafts and overdraft fees are making the news quite frequently these days. This increased attention often puts pressure on community financial institutions specifically, as the articles and reports are often unclear. Questions like, ‘is there something our FI is required to do?’ or more simply, ‘should we be doing something?’ arise.

Most recently, the Consumer Financial Protection Bureau (CFPB) has released a report stating that banks’ overdraft/NSF fee revenue has declined significantly compared to pre-pandemic levels. The CFPB stated that “Bank overdraft/NSF fee revenue was lower in 2020 and early 2021 than before the pandemic, which was likely largely due to pandemic-related stimulus checks pushing up average checking account balances. In the second half of 2021, as the pandemic stimulus wound down, overdraft/NSF fee revenue rebounded somewhat, but began decreasing again through the third quarter of 2022 – likely due to changes in bank policies.”

The CFPB states in their report that they ‘have not observed correlating increases in other listed checking account fees, which suggests that banks are not replacing overdraft/NSF fee revenue with other fees on checking accounts.’  The report identifies the largest banks in the United States, and while those banks can afford these changes, the report fails to review how this will affect community financial institutions.

It is important to understand that the comments in the report are a function of two primary things:

  1. Consumers have changed their behavior regarding overdrafts because of the pandemic.
  2. Mega banks chose on their own to drastically cut NSF and OD fees. Those banks have many revenue sources and can afford to be magnanimous, while community financial institutions do not have that opportunity.

Quite possibly the most critical message here is, there is no new regulation and nothing for the community FI to do, for now. Strunk will alert clients if any new rule making is introduced by the CFPB, and thus changes become necessary. Strunk’s overdraft program remains complaint by offering clear and appropriate disclosures, easily accessible reports and ongoing employee training.

Community FIs might still feel the strain of lost revenue and should explore new fee income strategies and profit improvement opportunities with Strunk to get out in front of this challenge. It has never been more important to shift focus and to diversify the ways fee income is produced for the community FI.

Banks see a Significant Drop in Fee Income

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Banks across the country saw a steep decline in fee income derived from overdrafts in 2020 likely due to pandemic related stimulus checks that pushed up consumer’s checking account balances. It bounced back somewhat in 2021 but there was another sharp decline in 2022.

Service charges that banks derive from overdrafts hit an all time high in the late 2000’s when the industry collected over $30B annually. In 2022 that number is less than $8B according to a recent report from the Consumer Financial Protection Bureau, a 75% drop in fee income. What happened and what can our industry do?

Consumer spending habits have changed and they are less likely to overdraw their account. Also, debit card regulations changed in 2010 which made banks get confirmation that a consumer wants their debit card paid at point of sale, even though they may not have enough money in their account. This was a great regulation and it gives the consumer a choice on how they want their account handled in the case of an overdraft. It also alleviated the problem for banks when they have to decide what to do in that situation. A win-win situation for consumers and banks.

Bankers for decades have been afraid to charge fees for services received by their customers. An example would be charging a fee for a checking account. Strunk’s Value Checking program has been around since 2011 and over 1,300 financial institutions have implemented it. Very simply, add benefits to all checking accounts and charge a small monthly fee on the account. ID theft protection, roadside assistance, and cell phone coverage are some examples of valuable benefits consumers are paying for elsewhere.

Contact Strunk at info@strunkaccess.com to learn more about Strunk’s Value Checking strategy. It is very simple to implement and consumers will like the service.

Strunk at the ABA’s Conference for Community Bankers 2023

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The American Bankers Association hosted this year’s Conference for Community Bankers in sunny Orlando, Florida from February 12-14 at the stunning JW Marriott Grande Lakes property. Attendees enjoyed a golf outing, Super Bowl tailgate party, Seussville reception and many engaging educational sessions.

This year’s keynote addressed employee retention, the “Great Resignation” and the “War for Talent”. Education sessions covered topics such as technology, payments, profitability, and lending.

Strunk was thrilled to debut their newest solution, Pricing Manager. Pricing Manager is a full-featured loan and deposit pricing solution that will provide banks with the ability to set loan and deposit pricing consistently and profitably. Commercial loans can be priced consistently by every lender – creating options for customers that all achieve the bank’s profitability targets. Additionally, rate sheets for consumer loans, residential mortgage loans, and deposits can easily be created that are also based on established profit objectives. Not only will Pricing Manager drive consistent achievement of profitability targets – it will also help you win more quality deals!

Strunk’s goal is to continually provide value-added SaaS solutions that help community banks increase profitability, while controlling operating expense. In addition to their latest offering, Strunk highlighted their overdraft service and best-in-class governance, risk and compliance solution, Risk Manager.

For more information on Pricing Manager or Strunk’s other solutions, visit https://strunkaccess.com/ or contact Strunk at info@strunkaccess.com.

 

Key Event History in ODP Manager

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Each day, an extract file is imported into ODP Manager to update each account with the most current data from the core. After the import, the letters due and the reports will reflect the up-to-date information – but what if a user needs to review the past information for a customer’s account?

Key account events are tracked within the software with each import and letter generated. After the file import completes, each account has been updated to note if the account is now closed, if it is now overdrawn, or if it has now moved into good standing. If overdraft limits were assigned or removed, or an account has opted in or opted out for Reg E, the account is also documented. When letters are generated, the hosted software updates the account’s history with the type of letter, the letter template, and the date. A PDF of the letter is also retained and linked to the event history.

In addition to these software-generated events, ODP Manager users can create their own events in the form of comments, reminders, repayment plans, and charge-off items. These items can be viewed and updated by all ODP Manager users.

Both comments and reminders are used to note additional information about an account and can include attachments. The main difference between the two is that a reminder will allow a user to specify the due date for follow-up action. Overdue and upcoming events display under the Events section of ODP Manager. Repayment plans create reminders for overdue fresh start payments. Charge-off items track the amounts charged off by account and can also track any recoveries received.

Please contact Strunk Support at support@strunkaccess.com with any questions or to find out more details about ODP Manager’s account event tracking.

Overdraft Privilege Provides a Much Needed Service

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Before the early 1990’s, banks typically returned all items that would cause an overdraft on a consumer checking account. When overdraft privilege programs started consumers were thrilled that their overdrawn items wouldn’t automatically be returned to the merchant. Thirty years later, Strunk, the pioneer of overdraft programs, is still helping banks provide efficient, compliant overdraft services to community banks across the country.

Overdraft programs have come under scrutiny since 2005 when the FFIEC published best practices for paying items into overdraft status. All of the guidance set forth by the regulators were meant to disclose the bank’s policies and to ensure those policies were followed…just like any product or service a bank offers.

In 2010 banks couldn’t automatically pay and charge for a debit card caused overdraft without consumer consent. Another great regulation! Then in 2011, the FDIC asked banks to provide notice to excessive users of overdrafts by notifying consumers each time that had six overdrafts in a twelve month period. Perfect solution to reminding customers of their bad habits!

More recently the FDIC has been concerned about disclosing second presentment fees on the same check. This occurs when an insufficient item comes through, the bank returns it to the merchant, and the merchant sends it back so they can get paid for the purchase the consumer made. Notifying consumers that a fee may be levied against the second presentment is a tremendous idea. There is also a concern that debit card transactions may be approved with a positive balance and when the item actually hits the account it is negative and an overdraft fee is charged.

Lastly, the CFPB is concerned about “junk fees” where someone makes a deposit then the check they deposited comes back insufficient. Some banks levy a charge for the insufficient deposited item even though the depositor wouldn’t have known that the check would be returned.

Contact Strunk at info@strunkaccess.com to learn more about how to run an Overdraft Privilege program in a compliant and profitable way that benefits consumers.

ODP Manager Letters as Needed

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The hosted ODP Manager software uses information from a daily extract file to determine when Collection letters should be sent to overdrawn accounts and which Custom letters should be sent to accounts when overdraft limits are assigned, or accounts opt in for Reg E. In addition to the Collection and Custom Letter functionality, the software also allows users the flexibility to send Ad Hoc letters as needed. These letters don’t rely on an account event to be triggered so users are not limited to criteria included in the daily extract file.

If you close and charge off an account before the standard number of days overdrawn, you will need to be able to generate an Account Closed letter. Or you may have ODP related letters that you send in specific situations other than those covered by the standard letter templates. You can even use Ad Hoc letters to generate your Fresh Start Loan agreements. Rather than creating letters manually, you can have Strunk set them up as Ad Hoc letter templates in the ODP Manager software.

If a user has a list of accounts that need to receive the specific letter, an Ad Hoc letter can be generated using the template, and sent to the customer. When you need to generate the letter, just enter the account number and the letter will pre-fill with the information from the software – name, address, and any other relevant fields. Letters can be generated one account at a time, or multiple account numbers at once. Once the letter has been generated, ODP Manager tracks and retains the letter just like your Collection and Custom letters.

Please contact Strunk Support at support@strunkaccess.com with any questions or to find out more details about using ODP Manager’s Ad Hoc letters.

The risks of working with vendors that have been sanctioned by the Office of Financial Assets Control (OFAC)

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Do you understand the risks of working with vendors who have been sanctioned by the Office of Financial Assets Control (OFAC)? How does this affect the way you manage your vendors?

The Treasury Department’s Office of Foreign Assets Control is known as OFAC. OFAC is in charge of managing economic and trade sanctions as part of the U.S. government’s effort to implement anti-money laundering/counter-terrorism funding laws. These sanctions are aimed at nations, people, or organizations who have participated in dishonorable behavior. In other words, they maintain a list of people and organizations that you should avoid doing business with. Because OFAC imposes trade and economic sanctions on foreign people and organizations that employ cyberattacks to endanger American foreign policy, national security, or financial stability, it has a strong following among security and risk management experts.

It is important to track your vendor’s OFAC report because it is yet another tool in the arsenal of . Here are a few pointers will help you get started:

  • Make sure to always verify key fundamental aspects to make sure you’re doing business with a legitimate vendor.
  • Perform an OFAC check on any new vendor you start a relationship with.
  • Include this check in your initial due diligence procedure and ongoing reevaluations.
  • Examine contracts to make sure that the necessary clauses are present.

Not only is it a good idea, but you should start doing an OFAC check on your vendors. For more information on Strunk’s Vendor Manager solution, contact us at info@strunkaccess.com

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.

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