Check-less or Cashless Society?

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Thirty years ago bankers were concerned that they might soon face a check-less society where most all debit transactions were no longer paper items. This was caused by the proliferation of debit and ATM cards that hit our industry. In the late 1980’s and early 1990’s banks saw Pony Express couriers pick up “cash letters” each afternoon and take them to the Federal Reserve or a correspondent bank for processing of the paper checks. Twenty years ago this practice slowed as the Fed allowed for electronic presentment of paper items deposited. In a recent report from the Federal Reserve less than 9% of all debits are paper…so we are getting close to a check-less society.

Now with the virus crisis our industry is seeing a shortage of coins from retailers across our communities. Some businesses are requiring exact change or debit card payments for the goods and services they sell. Also, with the substantial increase in purchases being made online, debit card or electronic transactions have grown significantly. There are other methods of payment such as Venmo, PayPal, and Apple Pay that reduce the need for consumers to carry cash. The question is “Are we getting closer to a cashless society as well?” This phenomenon has been exacerbated by trying to reduce the spread of the virus by not touching “anything”, including cash.

Banks have sought to help consumers take home the prescription drug or groceries from the store when they don’t have sufficient funds in their account. With debit card usage at an all time high, getting consumers to opt-in for electronic transactions is even more important. Letting consumers know they have a choice on how they want their account handled is good business. With paper checks and cash being used less, now is the time to review your overdraft payment process for debit card transactions.

Take advantage of new enhancements to Strunk’s Policy Manager

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This summer Strunk has been hard at work making value added changes to enhance all of our applications. Customers will be able to leverage the convenience and organization of Policy Manager now more than ever. Through our next release the solution will now include a suggestions feature, criteria based auto assignment and the ability to automatically make changes to users. Dan Roderick, Strunk CEO, said ‘we continue to improve our solutions monthly based on client input and are pleased to announce these latest updates’.

For users with view only access, we have added functionality to allow them to suggest changes to policy documents via a comment feature within the user interface. This will then allow editors or approvers the option to decide whether or not to implement the suggested changes.

Policy Manager will now support criteria based auto assignment for Reader and Editor Groups rather than administrators having to makes all policy assignments manually. The auto assignment will take place based on defined criteria including any combination of physical location, department, and job role. Assignment of a set of policies and procedures could dynamically change based on these rules.

Updates to user accounts has been streamlined with automation of user changes. To simplify adding new users and deactivating former employees, an automatic user file import can be set up. Once configured, a file containing all current users will be uploaded and processed via a scheduled task.

Policy Manager organizes your hundreds of policy documents spread across different computers and file systems into a single database. It provides a structured, single source of truth for your organization.

Is Your Overdraft Program Meeting the Needs of Your Account Holders?

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Strunk’s Overdraft Privilege program has helped financial institutions streamline the daily overdraft payment process for the past 27 years. Consumers would much rather have you pay an item into overdraft status than return it to the merchant…which only causes them grief. For debit card transactions that consumers want paid rather than denied at the point of sale, financial institutions must obtain consumer consent before paying those items and charging an overdraft fee.

The Overdraft Privilege Revitalization Program with Strunk ensures that a financial institution’s overdraft payment program is consumer friendly and compliant with current regulations and best practices. Like all bank services, overdraft payment policies and procedures should be fully disclosed to consumers, giving them a choice on how they want their account handled.

Our services include a four stage approach: 1) Review existing policies and procedures for paying overdrafts; 2) Make recommendations to improve the process; 3) Implement the time tested and proven strategies to ensure a high level of service and 4) Train your employees on the benefits of a fully disclosed overdraft privilege program.

Our recommendations cover four areas as well: 1) Compliance; 2) Account Holder Service and Education; 3) Operational Efficiency; and 4) Fee Income Enhancement.

Is it time to review your program to ensure what you are doing is meeting the needs of your account holders? Strunk has worked with over 1,800 financial institutions nationwide to help them implement a formal, fully disclosed overdraft payment process.

Importance of an Overdraft Privilege Service Policy

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Consumers should be provided an Overdraft Privilege Service Policy which discloses the limit, fees, and general practices before any limit is assigned, in addition to the standard deposit agreement and fee schedule. The Service Policy needs to be provided at program launch, new account opening or when a consumer account qualifies for Overdraft Privilege.

Disclosing your Overdraft Privilege Program clearly to the consumer in a Service Policy is a key element to any Overdraft Privilege Program.  Having an Overdraft Privilege Service Policy is important from a compliance perspective and it will also help improve the program’s performance because consumers will be more familiar with the features and limits.

Most financial institutions that have an Overdraft Privilege program either don’t have a Service Policy or they have a Service Policy that is not consistent with their other disclosures.  It is always important to be consistent with terminology regarding your program because these are sensitive points with regulators who fear use of different terminology could be confusing/deceptive for the consumer.

Strunk has a standard Overdraft Privilege Service Policy that we offer to our clients and is backed by our compliance guarantee.  Policies should be reviewed and approved by the Board of Directors annually, and as a Strunk Access client, your institution is entitled to assistance in ensuring your policy complies with any regulatory changes that may have occurred during any given year.  Strunk believes it is always better to voluntarily describe the specific benefits, features and limitations of products and services; and to tell consumers what the rules are.

Power your team through continuing education with Strunk’s Skills Manager

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If you are a Risk Assessor or Policy Manager user today, you may not be aware that Skills Manager is packaged with your solution. In order for your organization policies to be effective, your employees need to know the material. Skills Manager also lets you determine if your employees remember key aspects of those policies by periodically testing employee knowledge.

Through its Courses feature Skills Manager provides simple online training experiences to help your employees brush up on key policy details. For this online training you are able to create a library of training slides, either from text or exported from PowerPoint. You then will combine slides to develop courses and assign courses to your employees. It’s that simple! Users will then take courses via our online portal, with the ability to stop and pick up where they left off as needed prior to the due date.

Once Courses are complete you can then use the Exams module to test employee knowledge. Like Courses, you will create a library of exam questions that you can then assign to exams and then exams to users. Subsequently you will set parameters for frequency with which users must take exams and set parameters for a passing score or merit score. Your employees can show their knowledge of the material within each Course.

Strunk CEO Dan Roderick says “We launched Skills Manager V2 earlier this month and it’s easier to use than ever! It’s a great way to test employee policy knowledge and document results – particularly on those policies where periodic employee acknowledgement is required.”

Skills Manager also contains a user searchable document library for storing relevant reference materials that can be used as needed throughout the year.

ODP Manager Features to Streamline your Fresh Start Loan Process

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ODP Manager includes tools that may help you manage your Fresh Start Loan process.

For each account in a Fresh Start repayment plan, you can add the Fresh Start Loan repayment schedule. Payment reminders are created that display when due to remind you to check if the payment has been made as agreed. Once the payment is received, you can track the payment amount and date.

Also, you can easily create the Fresh Start Loan agreement using the ODP Manager account information and repayment schedule. Even if you choose not to track repayment schedules, you can still streamline FSL agreement creation by generating the document using ODP Manager.

The standard letter templates include an FSL Default close letter. If an account under a repayment schedule has defaulted and must now be closed and charged off, this letter can be generated and tracked in ODP Manager.

Do you send other Fresh Start Loan letters to accounts in repayment status? An Ad Hoc letter can be created for you to generate as needed – just enter the deposit account number and the letter will pre-fill with the account information. Once it is generated, it is tracked and retained within ODP Manager just like your Collection and Custom letters.

ODP Manager also includes a Fresh Start Tracking report that lists all accounts with a Fresh Start Loan Repayment ODP Status code. Use this report to monitor accounts currently in repayment or to identify accounts that have paid the Fresh Start Loan in full and should be reassigned an overdraft limit.

Let ODP Manager make managing your Fresh Start Loan process easier!

Consistency in Overdraft Privilege Training

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Overdraft Privilege programs have been around since the early 1990’s and they continue to benefit both consumers and financial institutions. Consistent and proper training of all employees on the benefits and pitfalls of a successfully run program remains important as we work through the Covid-19 pandemic.

Strunk has always recommended that all frontline personnel be trained on the features and benefits of operating an overdraft privilege program on an annual basis or as needed as turnover occurs. Returning overdrawn items on accounts only causes havoc for consumers and very few people want their paper debits denied when presented, even if it overdraws their account. For electronic debits including ATM and debit card transactions, financial institutions must obtain consumer consent before paying those items that cause an account to go negative. This gives consumers a choice on how they want their account handled.

Training should include the procedures on how your institution handles non-sufficient fund (NSF) items. Make sure that your procedure follows the institution’s policy on NSF items. Each employee opening new accounts should clearly convey how your bank’s overdraft program works. Pursuant to Regulation E, obtain opt-in if a consumer wants electronic items paid at point of sale rather than those debits being denied. Denied transactions keep the consumer from taking the groceries or prescription drugs home when using their debit card.

New accounts personnel also need to clearly discuss the fees associated with overdrawing the account.

Capping the total number of overdraft fees charged on a consumer account on any day is a best practice that is recommended by regulators. Also, waiving fees on small overdrawn amounts is also recommended.

Ongoing training is good for any service that your institution offers and consumer complaints are minimized when policies are transparent and communicated frequently. If you haven’t trained your employees on the features and benefits of your bank’s overdraft payment program, now is a great time to do so.

The importance of a thorough risk management process

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Managing risk is a fundamental process for any business and is crucial to achieve ongoing success for any company. Strunk’s Risk Manager solution provides a systematic process to ensure that you organization 1) knows your risks, 2) has policies to mitigate key risks, 3) is able to verify that policies are followed, and 4) can easily prove to others – management, board, examiners – that you follow this structured process. Risks may hinder or even prevent your business from achieving its goals, cause operational disruption, financial loss, or escalating cost. By performing a risk assessment, you can mitigate key risk indicators by taking them into account early on and developing action plans to reduce and effectively manage risk.

Risk management should not be confined to just one department in the organization or be the sole responsibility of a certain group of employees – it should be an integral part of everyone’s job. Strunk’s Risk Manager software will allow you to involve as many individuals in your organization as you like in the risk management process, keep all of the key components of your risk management process in one place, and gain a better understanding of the nature of the risks facing your organization. Many Risk Manager clients only use one or two modules but are not making full use of the entire solution. By using all of the modules in Risk Manager it will help you establish a more cohesive and stronger risk management environment. The new Version 2 of Risk Assessor is available and can help streamline your risk assessment process even further and save time. If you are a client that currently has Version 1, Strunk can help transfer results from Version 1 into Version 2 for no additional cost. Also, if you have staff members that have not yet been trained on any of the Risk Manager modules because they are new or their job responsibilities have changed, Strunk will do additional web based training for no additional charge.

Strunk is pleased to announce addition of FFIEC CAT Tool assessment component

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Financial institutions are at risk for an increasing amount and sophistication of cybersecurity breaches and threats. For this reason, the Federal Financial Institutions Examination Council (FFIEC) created a Cybersecurity Assessment Tool to help institutions identify the risks they face and to be sure they are prepared in the event they are faced with one of these events.

Strunk is pleased to announce the addition of this FFIEC Cybersecurity Assessment Tool to its Risk Assessor module. The feature is comprised of both the Inherent Risk Assessment and Maturity Assessment sections. Maturity Assessments are organized into domains: Cyber Risk Management and Oversight, Threat Intelligence and Collaboration, Cybersecurity Controls, External Dependency Management, and Cyber Incident Management and Resilience. Users must score their organizations on each question to determine their overall risk level. The Strunk approach to the assessment streamlines an otherwise cumbersome process so that financial institutions can much more easily complete these assessments and identify their maturity level.

Strunk CEO Dan Roderick says, “The FFIEC CAT is required for all financial institutions annually, so we are very happy to add this feature to Risk Manager at no additional charge to our clients.”

Clients have been using Risk Assessor to complete regulatory required internal risk assessments in days rather than weeks. The solution is preloaded with key risk indicators for BSA, ACH, Fair

Lending, Cybersecurity, Compliance, Asset Quality and much more. Call report data from your institution is automatically uploaded to the program quarterly to substantiate the risk. Concise board reports are easy to read and understand highlighting areas of high risk your bank faces.

Current Risk Assessor clients will receive the FFIEC CAT Tool for no change in their annual fee.  Please contact us if you are interested in viewing a demo of the tool.

Broker Dealers and Broken Controls

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Managing a financial advisory or brokerage firm is no small task; from finding clients, to advising the ones you already have, and everything in-between, compliance and governance can be a necessary burden.  While going through the vast regulations that shape the industry, the specific tasks of testing, preserving and repeating, are often asked.  Most firms utilize Excel, Word documents, and PDFs to build out their internal policies and controls in response to these regulations.  Almost all of these controls have a quarterly, bi-annual, or annual requirement to report activities, statements, or other documents to a host of stakeholders.  While utilizing an established Excel or SharePoint solution may seem like a “good enough” practice, the risk of missing one of these control events can be detrimental to your firm.

With a strong policy management software your firm can update processes to help save time, money, and reduce overall risk.  Strunk’s Controls Manager solution is one of the most intuitive products on the market, unwinding the complexity of your policy and compliance book, so you can automate your policy controls process and operation.  Through the use of a strong organizational system to address your regulatory obligation, your firm will have a more logical and considered approach to compliance, such as a Controls Calendar, enabling your company to effortlessly respond to your requirements.

While a patchwork of common Office tools seems like the easy and cheap solution, the downside risk far outweighs the upside risk.  Strunk can help you manage these risks, and put your firm on a better strategic footing.

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.