We have talked about: the creation of the vision for our loan portfolios (current state versus future state) – e.g. the strategy for moving our current portfolio to the future vision. Now comes the time for execution of that strategy. In changing portfolio composition and improving credit quality, the discipline of credit must be strong (this includes in the arenas of commercial loan origination, loan portfolio monitoring, and credit risk modeling of course). Consistency, especially, in the application of policy is key. Early on in the change/execution process there will be strong pressure to revert back to the old ways and stay in a familiar comfort zone.  Credit criteria/underwriting guidelines will have indeed changed in the strategy execution. In the coming blogs we will be discussing: assessment of the current state in your loan portfolio; development of the specific strategy to effect change in the portfolio from a credit quality perspective and composition; business development efforts to affect change in the portfolio composition; and policy changes to support the strategy/vision.  

As stated in an earlier posting, healthcare providers should ensure appropriate compliance with the Red Flags Rule.  There continues to be healthy debate as to what level of applicability the Red Flags Rule has in this market.  That said, the link below, to a recent article by the FTC, highlights some relevant points to think about as healthcare providers consider whether or not they are 'covered' and, if so, the appropriate measures to be taken in developing their Identity Theft Prevention Program.Of note, the article points out that "health care providers are creditors if they bill consumers after their services are completed. Health care providers that accept insurance are considered creditors if the consumer ultimately is responsible for the medical fees. However, simply accepting credit cards as a form of payment does not make you a creditor under the Red Flags Rule."  Based on this definition, it appears to some extent, that the majority of healthcare providers will be covered under the Red Flag Rule as creditors.I encourage you to have a look at this article if you are still on the fence: http://www.ftc.gov/bcp/edu/pubs/articles/art11.shtm

If the business is a creditor or a “financial institution” (defined as a depository institution) that offers covered accounts, you must develop a Program to detect possible identity theft in the accounts and respond appropriately. The federal banking agencies, the NCUA and the FTC have issued Guidelines to help covered entities identify, detect and respond to indicators of possible identity theft, as well as to administer the Program. A copy of the Red Flag Guidelines can be found: Federal Reserve Board – 12 C.F.R. pt 222, App. J Federal Deposit Insurance Corporation – 12 C.F.R. pt 334, App. J FTC – 16 C.F.R. pt 681, App. A NCUA – 12 C.F.R. pt 717, App. J Office of the Comptroller of the Currency – 12 C.F.R. pt 41, App. J Office of Thrift Supervision – 12 C.F.R. pt 571, App. J