Financial Institutions

Friday, 02 January 2015

Educating customers on safe online banking habits

Written by Rehmann Team

A new report from Juniper Research revealed that more than 2 billion mobile phone or tablet users will make some form of mobile commerce transaction by the end of 2017, up from 1.6 billion this year. Online banking usage is growing, too, as services like RDC and Mobile Deposit are becoming more widely offered and accepted. As reported in Bank News, more than half (51%) of respondents aged 18 to 34 who use mobile banking have adopted Mobile Deposit, while 36% of older consumers (age 55 and above) routinely use RDC...

Friday, 02 January 2015

FFIEC: boards need cybersecurity training

Written by Rehmann Team

The results are in. The FFEIC’s recently completed pilot program for cybersecurity risk assessments at more than 500 community banks revealed a serious lack of understanding of cyber threats among C-level banking executives. Federal banking regulators will soon be taking a hard look at community bank executives and boards of directors to evaluate their awareness, as well as the bank’s ability to anticipate, address, manage and monitor such threats. While bank leaders may not be asked why or how a certain type of attack happens from a technical perspective, they are likely to be asked during exams what their bank is doing to prevent and manage attacks, such as firewall penetration or DoS (denial of service) attacks...

Friday, 02 January 2015

SBA lending: know the risks, rewards

Written by Rehmann Team

According to the Small Business Administration (SBA), the mission of the SBA Office of Capital Access is to get lending flowing to small businesses to foster their long-term success. However, they also have an obligation to taxpayers to ensure tax dollars are being used wisely by mitigating risk and conducting oversight of its programs. Additionally, and arguably most important to the banking industry, they have an obligation to make good on their portion of the failed loans that they have helped make available to small businesses. A recent audit and evaluation of the SBA’s Portfolio Risk Management Program by the Office of the Inspector General (OIG) revealed that the SBA does not actually have a program in place to analyze risk across its $103 billion portfolio, and may have incurred unnecessary losses for taxpayers because it does not implement controls to avoid and monitor risk of default...

Friday, 26 September 2014

New TILA‐RESPA rule consolidates disclosures

Written by Rehmann Team

For more than 30 years, lenders have been required to provide four different disclosure forms to consumers when they apply for a loan and shortly before closing a mortgage loan. The information on these forms is repetitive and the language is inconsistent, making them confusing for consumers and burdensome for lenders and settlement agents to provide and explain. That’s about to change. Dodd-Frank Act (DFA) authorized the consolidation of these four disclosures into two disclosures that are easier for banks to educate and for consumers to understand...

Friday, 26 September 2014

Speak now or…

Written by Rehmann Team

Proposed HMDA Changes Open for Comment through October 22 The Home Mortgage Disclosure Act (HMDA) requires financial institutions to collect, report and disclose data about mortgage loans to help determine whether financial institutions are serving the housing needs of their communities, and to assist public officials in their determination of the distribution of public sector investments so as to improve private investment environment. HMDA also requires financial institutions to report racial characteristics, gender and income information on applicants and borrowers to identify possible discriminatory lending patterns and enforce antidiscrimination statutes. In a nutshell, it’s a lot of information to gather, verify, report, review, analyze and utilize. The latest proposed changes to HMDA are a whopping 5oo-plus pages long...

Friday, 26 September 2014

FFIEC cybersecurity pilot program raises awareness of third‐party risks

Written by Rehmann Team

It’s no surprise that the Federal Financial Institutions Council (FFIEC) has launched its cybersecurity pilot program at 500 financial institutions to raise awareness of third party risks. The assessments focus on the institution's handling of its risk management, risk oversight, threat intelligence and collaboration, and management of service providers and vendors. Although they are being incorporated into routine examinations, that doesn’t mean the assessments are quick, cursory reviews. Rather, the institution's leadership needs to be fully briefed, involved and prepared...

Friday, 26 September 2014

Income tax allocation agreements

Written by Rehmann Team

The Federal Deposit Insurance Corporation (FIDOC) recently issued an addendum to Policy Statement FIL-30-2014, Policy Statement on Income Tax Allocation in a Holding Company Structure (Interagency Policy Statement). The addendum pertains to intercompany tax allocation agreements and ensures that insured depository institutions (IDIs) in a consolidated group maintain an appropriate relationship regarding the payment of taxes and treatment of tax refunds. An intercompany tax allocation agreement is a contractual legal agreement pertaining to the computation of income taxes (current and deferred), payment of income taxes, and reimbursements to an institution when it has a loss for tax purposes.  A holding company and its subsidiary institution(s) are encouraged to enter into a written, comprehensive tax allocation agreement tailored to their specific circumstances...

Friday, 26 September 2014

FASB public interest entity definition and considerations

Written by Rehmann Team

In December of 2013 the FASB issued Accounting Standards Update (“ASU”) 2013-12, Definition of a Public Business Entity. The FASB definition is much broader than the previous definitions included within generally accepted accounting principles (“GAAP”). Whether an institution meets the new definition of a public business entity (“PBE”) requires careful analysis and may result in an answer that initially comes as a surprise. The new definition is to be applied in practice to determine which institutions will be able to avail themselves to new accounting alternatives developed by the Private Company Council (“PCC”) and other private company relief that the FASB provides in new standards...

Monday, 30 June 2014

Flood insurance changes

Written by Rehmann Team

In July 2012, Congress reauthorized the National Flood Insurance Pool (NFIP) for five years under the Biggert-Waters Flood Insurance Reform Act (BWA). This action supported real estate transactions for more than 5 million business owners and homeowners in 20,000 communities nationwide who rely on the NFIP and where flood insurance is required for a mortgage, according to the American Bankers Association. On March 21, 2014, President Obama signed the Homeowner Flood Insurance Affordability Act of 2014 (HFIAA) into law, effectively repealing and modifying certain provisions of the BWA. Changes of particular interest to financial institutions include: HFIAA Section 13 amends Section 102 of the Flood Disaster Protection Act (FDPA)...

Monday, 30 June 2014

Coming soon: cybersecurity assessments

Written by Rehmann Team

Cybersecurity: the technologies, processes and practices designed to protect networks, computers, programs and data from attack, damage or unauthorized access. The Federal Financial Institutions Examination Council (FFIEC) has not been shy about its enhanced focus on cybersecurity risk mitigation at smaller financial institutions. Actions have included the creation of the Cybersecurity and Critical Infrastructure Working Group, and the National Institute of Standards and Technology's issuance of the voluntary cybersecurity framework. Plus, in early April, the FFIEC issued warnings about Distributed denial of service (DDoS) attacks and ATM cash-out schemes targeting smaller institutions...

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