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Posted: May 24, 2018
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Author: Lou Grilli

ThePaymentsReview continues a new feature that occasionally highlights regulatory topics important to credit unions.

A major change to Remote Deposit Capture is coming this July, which may have an impact on whether financial institutions want to continue offering this service.

Mobile Remote Deposit Capture, or mRDC, is one of the shortest adoption curves of any aspect of online and mobile banking. Despite the slight decline in the number of checks written, recipients overwhelmingly prefer to deposit checks from the comfort of their phone, rather than going to a branch or ATM.  RDC was initially developed as a convenience for a business that received checks to deposit the checks electronically (typically using a scanner provided by its bank), and was made possible by Regulation CC, which implements the Expedited Funds Availability Act of 1987 (“EFA Act”) and the Check Clearing for the 21st Century Act of 2003 (“Check 21 Act”). Mobile remote deposit capture, and specifically, the ability for a fraudster or forgetful person to deposit a check by taking a picture using their smart phone, and then depositing the paper copy at a different financial institution or check-cashing business, was not taken into consideration by these two pieces of regulation. How often does this happen? 3.5 of every 10,000 checks deposited to banks and credit unions are duplicates according to the 2017 Mobile Remote Deposit Capture Industry Report.

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Immersion18, the first conference for the Trellance team under their new brand, incorporated the same insightful, educational and informative information as in the previous twenty-six years, but with a lot more collaboration and fun.

Tom Davis, President and CEO, kicked off this year’s annual conference stating “We have to be independent to be your best advocate.” Tom went on to explain that “While Trellance provides many of the same services it offered before, such as card processing; three words will drive its future: Independent, unbiased advocate.” Tom gave the four key factors toward credit union success: Hiring top talent, collaboration, having vision, and using data analytics. Bill Lehman, SVP of consulting services, spoke next, introducing some of the 17 new services offered by Trellance.

 

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Posted: Apr 11, 2018
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ThePaymentsReview continues a new feature that occasionally highlights regulatory topics important to credit unions.

Back on July 11, 2016 the Financial Crimes Enforcement Network (FinCEN) issued a rule requiring covered financial institutions to identify and verify the identity of any beneficial owner. The new Customer Due Diligence (CDD) rule takes effect May 11, 2018 at which time the financial institution must be compliant. For purposes of the CDD Rule, covered financial institutions are federally regulated banks and federally insured credit unions, mutual funds, brokers or dealers in securities, futures commission merchants, and introducing brokers in commodities.

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Posted: Mar 19, 2018
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Faster payments mean a vendor getting paid by its customer quicker, or getting a P2P transfer into the recipient’s bank account the same day. Automated Clearinghouse (ACH), the network that connects every financial institution, and makes payroll deposits, bill pay and business settlements possible, has been undergoing changes in phases. The phases represent incremental steps in the process to shorten the length of time it takes to make payments, from days to hours. The third phase of this transition went into effect March 16, 2018, and credit unions and their members, especially business owners, need to be aware of the impact. 

 

 

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Posted: Mar 6, 2018
Categories: Regulations, Consulting
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ThePaymentsReview continues a new feature that occasionally highlights regulatory topics important to credit unions.

Accounting for loan losses is at the heart of credit union accounting. Setting aside reserves for loan losses is an important accounting component, but an increase in allowances reduces a credit union’s capital. Under current accounting standards, a credit union recognizes losses when they reach a probable threshold of loss. This is called an incurred loss accounting model. In practical terms, incurred loss accounting is a backwards-looking model, measuring a pool of loans against historic annualized write-offs. This method can drastically underrepresent potential future losses when a loan portfolio is exposed to a financial crisis, especially after a run of several years with lower losses. And this is exactly what happened following the financial crisis of 2008 in which some credit unions found themselves under reserved and unprepared for losses in their loan and mortgage portfolios while losses to their investments, and in many cases, shares declined. In the rising economy of the early 2000’s, losses were not being accounted for as “probable”.

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