Glenn Onstad, CPA

Great article- take a couple of minutes to read it - especially if you have a leadership role at you financial institution. “The role of leadership in creating a Culture of Compliance cannot be overstated. Leaders have the unique ability to inspire, guide, and shape the attitudes and behaviors of their teams.” Great quote from the article 👏🏼

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Federal agency employees gained relevant resources and guidance using #GuidehouseExperts’ human-centered design to improve efficiency for critical project management processes. Explore how Guidehouse can help your organization enhance employee productivity and simplify access to critical resources. Guidehouse Technology Solutions | #ITStrategy #TechModernization #PMP #ProjectManagement #Businesstransformation  #HumanCenteredDesign

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On Friday, the Federal Reserve Board and Arkansas State Bank Department announced a cease and desist order with Evolve Bank & Trust. The order was issued amidst bankruptcy proceedings involving one of Evolve’s partners, BaaS platform Synapse, which has been widely followed. There’s plenty of commentary on the Evolve order, so I will just focus on one critical point I think will be underappreciated: The finding relating to capital. The order specifically calls out capital management, and requires the bank’s capital planning to be enhanced to “account for the Bank’s elevated risk profile, business model, [fintech partnership] activities, and fintech partners.” This is an often-overlooked element of partner banking: fintech partnerships are (rightly) perceived as elevating operational risk, and balance sheet growth can be unpredictable if not closely managed. The challenge with incorporating these risks into capital planning is that we don’t have very well-defined frameworks for calibrating capital requirements based on operational risk. Trust me, I’ve tried. I’ve developed capital frameworks for a couple clients for whom traditional balance-sheet based capital frameworks were clearly inappropriate. There was precious little guidance. The OCC issued guidance for trust banks in 2007 (see link in comments), because traditional balance sheet measures do not capture the risks of trust activites. The guidance identifies a number of factors for trust banks to consider, but does not offer a clear framework or any guidance on calibration. That is understandable: operational risk is hard to reduce to a standard formula that makes sense across a wide range of business models. The difficulties in developing a standard framework are on display in the banking agencies’ deliberations over the Basel III “endgame.” The new operational risk capital charge is the flashpoint in banks’ opposition to the proposal. What can partner banks do? In addition to thinking creatively about how to calibrate a management capital buffer for operational risk, they should conduct thorough forecasting of balance sheet impacts of their fintech partnerships, and have clear plans in place to manage fluctuations in assets and liabilities.   My partner Konrad Alt will write more on this aspect of the order, and you should check out his post as well. https://lnkd.in/e9kBPMTQ

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What fraud controls do you have in place? Are you vulnerable? Read the latest article from CTMfile on the results from the (AFP) 2024 Payments Fraud and Control Survey Report, sponsored by Truist. #fraudawareness

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It's been a minute but we're at it again - its FREE webcast time 😀 Don't miss out on our upcoming #fraud webcast on Thursday, May 2nd! Our panel of fraud subject matter experts, including Steve Lenderman, CFE, will be delving into all things fraud and #GenAI - how the technology is being used by fraudsters, how financial institutions are fighting back, and more! Secure your spot now! https://lnkd.in/gKny7A4q

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It’s a funny reminder that mistakes happen, even when we're the ones checking the work! This classroom scenario isn't too far off from what can sometimes occur in our own professional environments. 🏢💼 Imagine a manager or a reviewer guiding a team, only to point them in the wrong direction due to their own oversight. It happens more often than you might think! So, what can we take away from this? It's simple: foster an environment where healthy challenges to "corrections" are welcomed and encouraged. 🌟👏 This not only helps in catching those rare mistakes before they turn into costly errors but also promotes a culture of continuous learning and collective accuracy. Plus, it keeps us all humble and on our toes! Let's take it easy on the red pen and remember, two heads (or more!) are better than one when it comes to navigating the complex corporate world. A little humor and a lot of teamwork make for the best policies. 🙌🥳 #Teamwork #Leadership #CorporateCulture #ContinuousLearning #BusinessHumor

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Protecting Your Business from ACH Fraud Threats As a financial leader, safeguarding your company's finances is a top priority. And as you know, ACH transactions, which use sensitive bank account details, can expose your business to fraud risks. Fraudulent players are constantly finding new ways to exploit vulnerabilities, from phishing scams to cyberattacks and invoice spoofing. These threats not only put your organization's funds at risk but can severely damage your reputation and customer trust. There are powerful tools available to validate ACH transactions and mitigate fraud. At SIGMA ANALYTICS, we provide cutting-edge payment solutions with security features designed to protect your ACH payments. If you want to learn more about this please read this insightful and thorough blog post: "ACH Fraud: The Urgent Need for Validating ACH Transactions." Discover actionable strategies to fortify your defenses and gain peace of mind. SIGMA ANALYTICS REPAY - Realtime Electronic Payments #FraudMitigation #ACHPayments

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Our regulatory environment is becoming more active. The new FTC ban on noncompete's is interesting. For the banking sector, the FTC does not have jurisdiction over banks; however, they do have jurisdiction over bank holding companies. Thus, like many regulatory items, this one is nuanced and evolving. And as mentioned, it has already been challenged, e.g., by the U.S. Chamber of Commerce. More to come on this! https://lnkd.in/gu3enjTc

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As organizations look to adopt artificial intelligence (AI) to drive innovation and efficiency, it is critical to establish robust risk management and governance programs. Our experts recommend internal audit and risk managers consider the following:

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As organizations look to adopt artificial intelligence (AI) to drive innovation and efficiency, it is critical to establish robust risk management and governance programs. Our experts recommend internal audit and risk managers consider the following:

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I always look forward to our annual Citizens Business Outlook Report to see the key insights and challenges facing business owners. This year’s report shows companies that leverage insights effectively often report higher growth forecasts and a clearer understanding of their cash flow compared to their competitors. Find more data and considerations in the Citizens 2024 Business Outlook Report: http://spr.ly/6047iB8Lc. #CitizensColleague

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It’s not if but WHEN!!  We all have to do our part to ensure our Customers and Partners understand the financial risks that exist today. 

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As a business owner how do you stay up to date on recent trends and emerging technology. Personally I scour articles and websites, sign up for webinars, or ask a network of peers for best practices. Or maybe I just type the prompt into ChatGPT and see what it says!? We had Daleele Alison join us recently to discuss AI and emerging tech, and he provided a few great examples of how you can start using this in your day-to-day right away. Link is in post and comments.

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CAT – BOON or BOONDOGGLE? Originally published 11/16/2023 https://lnkd.in/grmhB4WH  I understand the reason and purpose of the Consolidate Audit Trail, (“CAT”).  It’s been in the works since 2010 (SEC Rule 613). But I don’t understand the purpose of another “agency,” not only collecting every trade that’s executed, but also collecting in detail, Personal Identifiable Information (“PII”) of every investor who buys even one share of stock. (This should not be confused with pi, whose value is approximately 3.14 or 22 to the power of 7. Pi is 3.141592653589793238462643383279502884197.)   Financial Professionals Coalition, Ltd. JOIN TODAY -- FREE MEMBERSHIP https://lnkd.in/g2peigti A CLEARING HOUSE OF SOLUTIONS FOR FINANCIAL PROFESSIONALS The Financial Professionals Coalition, Ltd. is a diverse resource for over 1.2 million registered representatives, associated persons, traders, bankers, back-office staff, and owners of broker-dealers and registered investment advisors. The Coalition provides courtesy consultations with industry experts. 

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In case you missed it! The recording is now posted. Listen to myself and 2 of the best AML Professionals in the business, Paul Achman, Daniel Schneider, CAMS as we discuss Best Practices for Banking as a Service (BaaS) for the ACAMS Greater Salt Lake City Chapter #acams #amlrightsource #amltraining #BaaS #FinTech

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The Office of the Comptroller of the Currency (OCC) recently released its Semiannual Risk Perspective for Spring 2024, outlining key issues impacting the federal banking system. According to the report, while the overall condition of the federal banking system remains strong, potential consumer headwinds due to the maturing economic cycle are a concern. It is crucial for banks to actively identify material risks and understand their interconnected impacts to mitigate any potential challenges. Highlighted in the report are key risk themes including credit, market, operational, and compliance risks. The data, as of December 31, 2023, serves as a basis for national banks, federal savings associations, and federal branches and agencies to address these critical areas. For more detailed insights, you can access the full report here: [OCC Report](https://lnkd.in/etbczu3Z) #OCC #BankingSystem #RiskManagement #Compliance #Finance

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