TOPIC: Procedures

TOMORROW: Mistakes & oversights that lead to third-party vendor problems and what your FI should be doing to prevent them.

Register for tomorrow's webinar here.

No one wants to be a vendor management cautionary tale—yet that’s exactly what happens to too many financial institutions. Why does this happen, and what can be done to prevent it? In our webinar tomorrow, we’ll review:
  • The most common vendor management missteps.
  • Lessons learned from recent enforcement actions.
  • Ways to reduce risk across the vendor management lifecycle.
  • The essential elements every vendor management program should have.
Don’t be caught flat-footed when it comes to vendor management. Make sure you know what to do—and what not to do.

Register here: https://hubs.ly/H0M8n6Z0

    GAP Insurance & Insurance check-Procedures

    VP at a bank ($147MUSA)
    I am looking for procedures to follow when consumer has wreck vehicle and it is a total loss.  Do you apply the Insurance check to the principal only?  Do you roll the due date? At what point do you notify the customer of receiving the Insurance check?  Is there a letter you send to customer?  Who notifies GAP Insurance if the loan is an Indirect Auto Loan? If after Insurance Check & Gap Insurance is applied and their is a balance is their a letter you can send to the customer? (Examples)  Any help in establishing some guidelines for Loan bookkeeping & Loan Officers to follow would be very helpful.  Right now we have no procedures, just information passed down from one employee to another.  Looking for something a little more formal. Thank You.    

      How Not to Manage Vendors: Strategies for Avoiding Costly Vendor Management Mistakes | Free webinar!

      Register for the webinar:
      Thursday, April 29, 2021 @ 2:00 PM CT


      No one wants to be a vendor management cautionary tale—yet that’s exactly what happens to too many financial institutions. Why does this happen, and what can be done to prevent it?

      Join us as we highlight the strategic mistakes and oversights that lead to third-party vendor problems and what your institution should be doing to prevent them. We’ll review:
      • The most common vendor management missteps.
      • Lessons learned from recent enforcement actions.
      • Ways to reduce risk across the vendor management lifecycle.
      • The essential elements every vendor management program should have.
      Don’t be caught flat-footed when it comes to vendor management. Make sure you know what to do—and what not to do. Register here: https://hubs.ly/H0J_r4q0

        Address Confidentiality Program (ACP)

        Manager at a credit_union ($310MUSA)
        Hi everyone, we are in the process of developing our procedures in regard to members who participate in state sponsored Address Confidentiality Programs (ACP).  From a risk stand point, I am curious how other financial institutions are handling real estate lending and consumer lending when Address Confidentiality Program participants are involved, especially when considering the possibility of repossession on a secured loan.  Any insight is very appreciated!

          Breach of Confidential Information

          Employee at a bank ($459MUSA)
          We are looking at revising our current procedures on Breach of Confidential Information including how to report, who to report too and additional training.  Does anyone have procedures/policy they would be willing to share? Also, any training on Breach of Confidential Information? or where i can find training?  There is allot for IT Security but we are looking at breach of information ex. paper work, personal info, etc.

            Complaints- UDAAP Root Cause Analysis

            Employee at a bank ($7.3BUSA)
            If you identify a potential UDAAP concern within your complaints and need to investigate further, what does that process look like for you? Do you have an official procedure or a special root cause analysis form? 

            We are currently reviewing our CMS and the conversation turned towards potential UDAAP concerns. I wanted to reach out and see what others are doing because I have not found much when researching. The only specific reference I have found was from the OCC UDAAP handbook released last summer. It states we should conduct a root case analysis and assign appropriate corrective actions should the analysis identify deficiencies. We monitor for UDAAP using word searches and review complaints for trends. While we have never uncovered a UDAAP concern and we don't anticipate it happening, I want a plan in place so we're prepared. Thank you for any feedback you're able to provide. I appreciate it!

              GL Cash Item Account

              AVP at a bank ($254MUSA)
              Does anyone have any procedures on reconciling the CASH Item GL account?  
               For example what goes into this account, etc.. We have had some staff changes in the Deposit Operations area and the person taking over that area is not able to determine if we every had any or able to locate anything.  We are trying to close out an audit hopefully today and they are asking for this. Thanks,Tamara

                CDD Checklist | Free Download

                Customer Due Diligence (CDD) is commonly known as the fifth pillar of Bank Secrecy Act (BSA) compliance. Your CDD program should be risk-focused, and periodic risk enhanced due diligence (EDD) reviews should be conducted for higher risk customers and entities. CDD can seem overwhelming for institutions with a limited budget. However, regulatory guidance is improving and should be used to help evade CDD findings.

                This whitepaper outlines four key strategies for financial institutions to leverage to enhance their CDD program prior to upcoming exams. 

                Download this whitepaper to learn:
                • How to assess higher-risk customers
                • How to map and analyze processes to identify opportunities for efficiency gain 
                • How to address gaps within the current processes and enhance procedures
                Download the attached CDD/EDD checklist for additional guidance on a strong CDD program.