No better time to implement a Cloud-Based GRC Solution

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Over recent weeks, the ongoing spread of the COVID-19 coronavirus has forced companies around the country to make difficult decisions about how to protect their employees — as well as their communities as a whole.  In an effort to halt the spread of the virus, many organizations are instituting mandatory work-from-home (WFH) policies, engaging with new cloud service providers, and shifting resources toward supporting an expanding remote workforce.  The fast-moving, global reach of the coronavirus has illustrated that a forward-looking approach to risk management is more important than ever. Having a cloud-based tool that streamlines your compliance process should be in all companies’ future strategic discussions.

Strunk offers many great automated cloud-based solutions tools that streamlines compliance and risk management for our clients.  There are many benefits to these cloud-based solutions, especially in today’s environment where some many employees are working from home.  Our software is simple to implement, easy to access, very flexible and is reliable in terms of backing up data for your employees who are at different locations.  Implementing Strunk’s Risk Assessor, Policy Manager, Issue Manager and Vendor Manager software does not require extra hardware or software.  Implementing these tools can be done while business continues as usual which requires no downtime at all.  Strunk has created a new Version 2 of our Risk Assessor which is available to everyone.  Risk Assessor helps our clients complete risk assessments consistent with appropriate regulatory or standards body frameworks in days, instead of weeks.  Clients are able to upgrade for free from Version 1 to Version 2 and Strunk will help transfer results from your current Version 1 assessments.

Given the current coronavirus pandemic, the need for companies to centralize their policies and vendor management is more critical than ever.  Strunk’s Policy Manager software will organize hundreds of policy documents spread across different computer and file systems into a single editable database. With employees working remote, Policy Manager gives employee access to the companies polices for easy access and with the established review dates the system will remind employees to review the policy and make changes.  Centralizing your vendor manager process with Strunk’s Vendor Manager software will automate the process which reduces administrative burden and save time while giving employees who are working remote access to vendor due diligence, providing a practical framework for deciding which vendors to assess in depth, assessing the risks each vendor present, and the monitoring of each vendor performance.

Also, Strunk is offering additional free web training for our client’s employees.  There is no better time than now to get employees who are new or have changed job responsibilities trained on any of Strunk’s GRC software.

Strunk Policy Manager Software Now Includes GRC Policy Templates

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In 2015 Strunk launched Risk Manager which has now evolved into a full featured Governance, Risk Management, and Compliance (GRC) solution including Risk Assessor, Policy Manager, Controls Manager, Vendor Manager, Issues Manager, and Skills Manager tools.  Today, as an added service for Risk Manager clients, we are announcing the availability of standard template policies for banks, credit unions, investment advisory firms and broker-dealers.

Policy requirements evolve, and often times organizations find that their existing policy has become outdated, or they don’t have a policy at all to address a particular issue.  No one wants to write a new policy from scratch – particularly regarding a complex issue. So, starting with a vetted template and customizing it to your particular organization is a big benefit both in terms of making sure the policy is complete and saving time. There are a variety of companies that provide policy templates for a fee.  But with Strunk, they are free for Risk Manager clients.

Dan Roderick, Strunk CEO said, ‘Clients have been asking us for quite some time if we can provide them with a specific policy that they don’t currently have in their existing policy manual and each time we would track down a template example for them.  Now we have assembled a database of standard documents to respond to those requests.  In fact, if a client were to ask for an entire manual of standard policies, we can now easily provide those documents.  Policy Manager has been one of the most popular components of the Risk Manager solution – it was the first module we developed five years ago.  This should be a valuable enhancement to our GRC solution.’  The current COVID-19 crisis is one example of an event that can create a need for a new or more thorough policy.  The Pandemic Policy and Plan documents have been frequently requested during the past month.

Can Strunk’s ODP Manager Software Lighten Your Load?

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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

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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

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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.

Is your firm ready for the change in Regulation BI (Best Interest)?

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In June 2019 the United States SEC put forth changes in the way broker dealers and investment advisors deal with their customers, creating a fiduciary responsibility, and clear reporting of how your firm might be earning money from services and products provided to your clients.  These changes, while good for consumers, have created a regulatory burden on the industry to update policies and procedures, as well as formulating new ways to disclose your firm’s relationships with vendors and investment products.

The new regulation requires registered broker dealers and investment advisors to provide retail investors with easy to understand information about the confines of their relationship with your firm, ensuring potential clients can clearly see the differences between firm conflicts, fees, and other determining factors.  This has led to the creation of the CRS relationship summary form, as well as several other less formal processes all firms in the space must comply with.

While the rule changes happened in June 2019, the SEC gave the industry until June 30, 2020 to conform to the new requirements. It is generally recognized that all broker dealers and investment advisors will need to make changes to their operations, mandatory disclosures, marketing materials, and any system used for compliance.

If your firm is currently utilizing Excel, Word, and PDF documents to create your Policy Manual, it’s time to upgrade to a system that can help with the Reg BI changes and all your policy and risk management needs.  StrunkAccess provides an easy to use Policy Automation tool, allowing your firm the flexibility to find, and organize your policies in a logical way; helping to ensure compliance within your company.  Contact us today to find out more about how we can help your company achieve compliance for your regulatory needs.

Policy Management Made Easy

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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.

Strunk is pleased to announce the expansion of their offering to serve investment advisory firms and broker-dealers

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For over 40 years Strunk has been proud to work with financial institutions across the country to provide fee income strategy, risk management and compliance solutions. We are now bringing the power and reliability of our software applications to serve investment advisory firms and broker-dealers.

Any organization wants to be sure it has adequate policies and procedures in place to address the risks it faces. Strunk’s Policy Manager application is the perfect tool to help organize and manage these documents into a firm’s comprehensive compliance manual.

Due to the breadth of rulemakings and interpretations brought forth by the Securities and Exchange Commission that these organizations must adopt, internal policies and procedures are not only numerous but can be difficult to maintain. Strunk’s Policy Manager provides a structured, centralized single source of truth for this documentation.  Dan Roderick, Strunk CEO commented, “Five years ago, our very first client for Policy Manager happened to be a broker-dealer and investment advisory firm, so it only makes sense for us to place additional focus on that market”.

The solution features linkage of procedures to polices, automated change logging, as well as the ability to add multiple file attachments to each document. It is also possible to map policies to relevant risk assessment frameworks to make sure all bases are covered.

Additionally, the ability to assign ownership responsibilities at the section or individual policy level will provide granular control over read, edit and approval rights. Companies will be able to track employee acknowledgement of reading specific policies through application logs and reports. When users make changes to documents these updates will be automatically logged and logs can be filtered by particular time period or user.

PDFs can be produced from all documentation for external consumption along with redline versions of policy changes for comparison.

 

Make ODP Manager Letters and Events Work for You!

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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

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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.

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.