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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...
By: Tom Hannagan For the last 16 months or so, the financial services industry has been indicted, tried, found guilty, sentenced and duly executed...
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...
We get the following question quite a bit: Would the regulators expect to see a log of detected activity and resulting mitigation? Short answer:...
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...
It is the time of year during which budgets are either in the works or have been completed. Typically, when preparing budgets, we project...
By: Tom Hannagan In several posts we’ve discussed financial risk management, the role of risk-based capital, measuring profitability based on risk characteristics and the...