Financial Services
I’ve talked (sorry, blogged) previously about taking a risk-based approach to reconciling initial Red Flag Rule conditions in your applications, transactions, or accounts. In...
Hello Red Flaggers! I’m still getting some questions from our clients these days around the FTC enforcement extension. My concern is that there seems...
By: Tom Hannagan Here’s a further review of results from the Uniform Bank Performance Reports, courtesy of the FDIC, through the third quarter of...
By: Tom Hannagan I reviewed the Uniform Bank Performance Reports (UBPR: (http://www2.fdic.gov/ubpr/ReportTypes.asp ) for selected clients through the third quarter of this year. The...
We continue to receive inquiries from our clients, and the market in general, around whether they are required to comply with the Red Flag...
We have talked about: the creation of the vision for our loan portfolios (current state versus future state) – e.g. the strategy for moving...
In my last blog, I talked about the overall need for a vision for your loan portfolio and the similarity of a loan portfolio...
By: Tom Hannagan I was hoping someone would ask about this. Return on Equity (ROE) is generally net income divided by equity, while Return...
The Federal Trade Commission (FTC) suspended enforcement of the new Red Flag Rule until May 1, 2009. According to the FTC’s Enforcement Policy, “…during...
I’m working with many of our clients in reviewing their existing or evolving Red Flags Identity Theft Prevention Programs. While the majority of them...
As someone heavily engaged with the market and our clients discussing Red Flag Rule compliance, Red Flag guidelines, etc…this question has come up over...
By: Tom Hannagan In previous posts, we’ve dealt with the role of risk-based capital, measuring performance based on risk characteristics and the need for...
One of the more significant operational concerns around Red Flags compliance centers on the management of resultant referral volumes, i.e., the potential that the...
Whenever an industry encounters problems, the natural tendency is to play the blame game. In the banking industry, credit risk managers are looking for...
By: Tom Hannagan In my last post, I addressed the need for banks to advance their management of risk to include the relationship between capital...
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