Latest Posts
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...
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...
The pendulum has definitely swung back in favor of the credit discipline within financial institutions. The free wheeling credit standards of the past have...
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...
By: Tom Hannagan In previous posts, we’ve dealt with the role of risk-based capital, measuring performance based on risk characteristics and the need for...
Just as with diet recommendations, moderation needs to be the new motto for credit risk management. Diets provide for the occasional bag of chips...
By: Tom Hannagan The problem in the 2005 to 2007 home lending frenzy was not just granting credit to anyone who applied. It was...
One of the more significant operational concerns around Red Flags compliance centers on the management of resultant referral volumes, i.e., the potential that the...
Whenever an industry encounters problems, the natural tendency is to play the blame game. In the banking industry, credit risk managers are looking for...