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.

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.

 

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.