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FDIC Institutions still getting UIGEA (Reg GG) findings – UPDATE
Update 1 – 12/5/2011 to add examination procedures*. Update 2 – 2/13/2012 to emphasize policy requirements. Update 3 – 10/8/2012 to add specific courses of action Read the rest of the article
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BYOD Redux – The Policy Dilemma (Part 1)
Employee-owned mobile devices are everywhere, and they’re being used for everything from email to document storage and editing. Proper risk management procedures are defined in your policies, but do you need a separate mobile device policy, or can you simply mention them in the same policy sections that address other portable devices? Or is there…
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“Operational Risk Increasing”
In a recent speech to the Exchequer Club1, Thomas J. Curry, the new head of the OCC, stated that although asset quality has improved, charge-off rates have fallen, and capital now stands at its highest level in a decade, another type of risk is gaining increasing prominence; Operational Risk. “Some of our most seasoned supervisors,…
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CFPB Examinations Are Coming – UPDATE 2
Coming soon to your financial institution: Dear Board of Directors: Pursuant to the authority of the Dodd-Frank Wall Street Reform… Read the rest of the article
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FDIC offers “Insight” on Mobile Banking
Although not considered official supervisory guidance, the most recent FDIC Supervisory Insights newsletter offers an instructive early look into how the agency might examine this emerging electronic banking delivery method in the future. (Before you tune out and decide to wait for the formal guidance, remember it was the Winter 2009 issue that first introduced…
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Online Transactions – Defining “Normal”
I’ve gotten several inquiries about this since I last posted so I thought I’d better address it. The new FFIEC authentication guidance requires you to conduct periodic risk assessments, and to apply layered controls appropriate to the level of risk. Transactions like ACH origination and interbank transfers involve a generally higher level of risk to…
