Sunday, September 20, 2020

SIEM System Protection for Your Financial Institution

Posted by OnCourse Staff May 17, 2019 2:27pm
Sample Image Photo Credit: everythingpossible ©

In today’s technology environment, financial institutions are consistently searching for ways to secure their network. However, many institutions do not take full advantage of monitoring tools that may enhance their security and safeguard their network. For these institutions, a Security Information and Event Management (“SIEM”) system may provide the additional protection needed.

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Flood Coverage – Still a Hot Regulatory Issue

Posted by OnCourse Staff February 20, 2019 2:42pm
Sample Image Photo Credit: Galina Peshkova

Flood certifications, coverage, insurance, and placement – these are common in any financial institution’s compliance vocabulary nowadays. It’s no secret that all regulatory agencies have had “flood” as a hot topic for the past few review cycles. Financial institutions have been reinforcing their knowledge and awareness of the issue. Yet, even with all of the training that banks and credit unions have paid for and had their employees attend, why are financial institutions still receiving flood violations?

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Interagency Statement on Sharing BSA Resources and Challenges

Posted by OnCourse Staff December 7, 2018 7:34pm
Sample Image Photo Credit: semisatch

On October 3, 2018, an Interagency Statement was issued by five agencies/regulatory bodies to provide banks with an option to enter into a collaborative arrangement involving two or more banks to share their available resources in order to ensure compliance with Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”) requirements...

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Improving Cybersecurity Governance

Posted by OnCourse Staff July 18, 2018 2:34pm
Sample Image Photo Credit: iStock

The risk landscape for financial institutions is constantly changing with a myriad of new regulations and growing cybersecurity threats. In this environment, surveys continue to show that Boards of Directors and Senior Management lack confidence in their institution's cybersecurity capabilities and that cybersecurity governance is often inadequate...

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Sample Image Photo Credit: Stuart Miles

This past weekend, the New Jersey Legislature and Governor Murphy came to an agreement on Corporate Business Tax ("CBT") changes in connection with the State's 2019 fiscal year budget...

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Enhancing Data Protection

Posted by OnCourse Staff April 4, 2018 3:23pm
Sample Image Photo Credit: Marina Putilova

With the advent of new regulations, such as NYDFS Part 500 Cybersecurity Requirements and General Data Protection Regulations ("GDPR"), more focus has been placed on securing data in transit and data at rest...

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Correspondent Banking: The Challenges of Data Transparency

Posted by OnCourse Staff January 25, 2018 4:27pm
Sample Image Photo Credit: stocksnapper

As institutions continue to face challenging regulatory regimes and examinations, there are certain takeaways that banks, especially domestic branches of foreign banking organizations (“FBOs”), can benefit from, and adapt to, as a result...

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Regulation E and Business Account Errors

Posted by OnCourse Staff November 6, 2017 2:59pm
Sample Image Photo Credit: olegdudko

I was asked this week, how and when does Regulation E apply to business customers if they report a claim? My answer: it doesn’t, but it could...

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A Lesson in Equifax

Posted by OnCourse Staff September 17, 2017 4:44pm
Sample Image Photo Credit: J.R. Bale

At this point, we have all heard about the Equifax breach that has affected approximately 143 million U.S. consumers along with certain citizens in the UK and Canada...

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Controls over Employee and Officer T&E Expenses

Posted by OnCourse Staff August 16, 2017 11:05am
Sample Image Photo Credit: Galina Peshkova

Over the past year, we have seen the regulators more closely scrutinizing banks’ expenditures as they relate to Officer’s Travel and Entertainment (“T&E”).  Depending upon the nature of the bank’s business, asset size, and officer structure, controls in this area might vary greatly. However, one thing for sure is that we are moving towards the fact that institutions should have an adequate process in place to address their specific risks...

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Is Regulation CC Put on the Back Burner?

Posted by OnCourse Staff August 15, 2017 4:36pm
Sample Image Photo Credit: prykhodov

Regulation CC was enacted in 1987 in order to standardize hold periods on deposits made to banks and to regulate a bank’s use of deposit holds. There have been many changes throughout the years, but one in particular is that all checks are considered local and clear on a much timelier basis than in earlier years. One thing that remains unchanged is Regulation CC applies to both personal customers and commercial customers...

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Training – An Investment and Risk Management Tool

Posted by OnCourse Staff August 15, 2017 1:19pm
Sample Image Photo Credit: Mikko Lemola

Throughout my entire career in the banking industry, I have been a strong – actually make that an obnoxious – advocate for employee education and training. As a C-level executive at several institutions, I have both encouraged and required staff to seek out any and all seminars, conferences, schools and vendor programs...

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Are You Gambling with Your BSA Program?

Posted by OnCourse Staff June 27, 2017 12:16pm
Sample Image Photo Credit: Vitaliy Kytayko

It’s that time of the year again for your BSA/AML compliance audit.  We know how much you enjoy it when your BSA internal auditors show up with smiles as big and long as their request memos and sample sizes – from policies to procedures...

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ADA Website Compliance: For Whom the Bell Trolls

Posted by OnCourse Staff April 21, 2017 11:30am
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Over the last year or so, banks have been heavily focused on complying with the latest cybersecurity laws and regulations -- as they should be -- but lately, it has been a much older law that has been causing compliance and financial stress...

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The Case of Foreign Banks and Heightened Scrutiny

Posted by OnCourse Staff March 24, 2017 2:35pm
Sample Image Photo Credit: Kheng Ho Toh

There is what appears to be a trend happening in the foreign branch banking market that seems all too consistent. That trend is the influx of MRAs, MOUs, and Consent Orders being handed down by the federal regulators for having insufficient BSA/AML and OFAC compliance programs.

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IRS and New Jersey Tax Audits of Banks

Posted by OnCourse Staff March 16, 2017 4:57pm
Sample Image Photo Credit: Val Goretsky

Budget deficits and other fiscal concerns combined with challenging economic conditions continue to place pressure on federal and state governments to generate increased revenue through tax collections...

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State Taxation of Financial Institutions in Today's Environment

Posted by OnCourse Staff February 24, 2017 7:29pm
Sample Image Photo Credit: Megan Shull

Among the most challenging areas of taxation confronting banks today are the state tax ramifications resulting from the institution's business activities. With the prevalence of Internet-based activities, expansion of services offered by banks and extended geographic reach, the evaluation of state tax implications is much more complicated and requires greater analysis.

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Does your 401(k) Plan need an Audit?

Posted by OnCourse Staff January 25, 2017 12:32pm
Sample Image Photo Credit: adiruch

The July 31st reporting deadline for employee benefit plan Form 5500s will be upon us in the blink of an eye; it’s important for banks to be familiar with the 401(k) audit compliance rules before it’s time to file.

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De-Risking of Foreign Correspondent Banks

Posted by OnCourse Staff January 24, 2017 5:36pm
Sample Image Photo Credit: Michael Borgers

On October 5, 2016, the Office of Comptroller of Currency (“OCC”) issued guidance relative to foreign financial institutions de-risking policies with respect to maintaining foreign correspondent banking relationships.

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Same Day ACH Credits – Phase One

Posted by OnCourse Staff October 24, 2016 2:07pm
Sample Image Photo Credit: Daniil Peshkov

In today’s environment, we want everything faster, especially when it comes to our finances. National Automated Clearing House Association (“NACHA”) has adopted a new rule that will enable same-day processing for ACH credits received by the Receiving Depository Financial Institution (“RDFI”).

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NYDFS considers requiring CISOs for all NY Financial Institutions

Posted by OnCourse Staff September 26, 2016 11:45am
Sample Image Photo Credit: Leo Wolfert

Last fall, the New York Department of Financial Services (“NYDFS”) released a statement regarding potential new regulations aimed at increasing cybersecurity defenses at financial institutions. Fast forward to one year later and the NYDFS ups its game once again. In September 2016, the NYDFS proposed new cybersecurity requirements to protect New York State Financial Institutions and consumers, a “first-in-the-nation regulation"...

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Sample Image Photo Credit: Scandinavian Stock

As the saying goes, the chickens have finally come to roost. FinCEN and the banking authorities have issued a final ruling on beneficial ownership with respect to Customer Due Diligence, now requiring financial institutions to identify beneficial owners of covered businesses as part of the account opening process.

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Keep an Eye On Your Chip!

Posted by OnCourse Staff August 1, 2016 5:38pm
Sample Image Photo Credit: alicephoto

By now, a lot of credit card and debit card companies in the U.S. have begun to issue cards with the new “chip” technology. Here’s a little background on the chip card technology and its unfolding in the U.S...

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Is the IRS Status of your Defined Benefit plan in Jeopardy?

Posted by OnCourse Staff July 8, 2016 2:17pm
Sample Image Photo Credit: lightwise

Electronic certification (“e-certification”) for loans and hardship withdrawals, without the retention of appropriate supporting documentation, is considered a QUALIFICATION FAILURE.

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Sample Image Photo Credit: David Carillet

We’ve all come to the realization that the legalization of marijuana in the U.S. is something that is becoming more and more prevalent. As state legislatures and lawmakers have since softened their policies on marijuana usage (medicinal or recreational) and begun to see the monetary benefits of legalizing such at the state level, there still presents a heightened risk of money laundering in the banking industry.

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