Part 1 In reality, we are always facing potential issues in our small business portfolio, it is just the nature of that particular beast....
I have heard this question posed and you may be asking yourselves: Why are referral volumes (the potential that the account origination or maintenance...
What is your greatest concern as the May 1, 2009 enforcement date approaches for all guidelines in the Identity Theft Red Flags...
By: Tom Hannagan I have referred to risk-adjusted commercial loan pricing (or the lack of it) in previous posts. At times, I’ve commented on...
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...