6/1/2023
As we inch closer to marking a quarter of the way through the 21st century, one thing has become very apparent: the 21st century is anything but stable. In 22 years, the world and its economies have endured the threat of international terrorism, a global banking crisis, a worldwide health pandemic, high inflation here in the US, and overseas, the largest European conflict since World War II. Each incident presented unique challenges to consumers and businesses alike, but one thing remained constant: fraud.
4/10/2023
The Financial Institutions practice group at Saltmarsh brings you The Payments Professor to discuss operational and other issues financial institutions should know for FedNOW implementation. Access the webinar on demand!
3/1/2023
Are you a Bank, Credit Union or Third-Party Sender that originates Micro-Entries on behalf of your customers? With Micro-Entries (Phase 2), risk management requirements will be applied to all Originators of ACH Micro-Entries. Enforcement of this requirement begins March 17, 2023.
12/14/2022
We often get the question. “Do I need an ACH audit?” The general requirement per the Nacha Operating Rules is that a bank or credit union (DFI) must conduct, or have conducted, an audit of its compliance with these Rules annually. However, other parties involved in processing ACH transactions need an ACH audit, too.
12/5/2022
In this webinar, Senior Financial Institutions Consultant, Sallie O’Brien, AAP, APRP, will discuss today’s top audit findings and best practices to stay in compliance with Nacha Operating Rules for financial institutions. Access webinar materials here!
10/27/2022
As we’ve previously noted, most of the CECL-related focus has been on loans receivable, and to a lesser extent, debt securities. Are there any other financial assets that fall under the CECL guidance? The answer might surprise you.
8/31/2022
For the past 17 years, the Saltmarsh Bank Advisors have brought hundreds of financial institution professionals together for community banking events, BankTalk, to learn about advancements in the industry, regulatory updates and much more. With the turn to virtual after 2020, the team hosted the last three annual events virtually – but that didn’t stop them from getting an insightful lineup of speakers and content!
8/17/2022
Is your bank approaching $500 million in assets? Have you already crossed that threshold recently? As your bank continues to grow, your reporting needs may change due to FDICIA regulations. Saltmarsh is here to help ensure you remain compliant and that your bank has the resources, time and expertise to meet regulatory requirements.
8/11/2022
Many financial institutions require a written indemnification agreement to be completed in connection with requested ACH returns. This is especially the case when the return of funds cannot be completed using an ACH return entry (i.e., an R06 Return Reason Code) or funds are returned outside the ACH Network (i.e., via wire or check).
8/10/2022
Back-testing has been challenging during this COVID period due to large volume variances and asset yield variances caused by high loan and deposit growth coupled with forecasts not incorporating PPP loan-related fees.
7/25/2022
When I was asked to repurpose a blog I wrote almost 10 years ago, at first, I thought it would be hypocritical of me. I had written four recommendations to help my business clients achieve peace and strength during a time of unprecedented change, and unfortunately, I had not been practicing my own recommended behaviors, despite being bombarded with changes!
7/21/2022
In this webinar, Financial Institutions Senior Consultant Janice Weisz, AAP, will provide a high-level overview of upcoming rules associated with Micro-Entries.
7/12/2022
Micro-Entries are a generally accepted method in the marketplace for an ACH originator to test the validity of a receiver’s account. Although originators have used this low-cost option for quite some time, Micro-Entries are not defined within the Nacha Operating Rules.
6/15/2022
For those of you working diligently in the financial industry, we remind you that June is Elder Financial Abuse month. Elder financial exploitation (EFE), a form of Elder Abuse, is the most common form of elder abuse. EFE is defined as the illegal or improper use of an elderly adult's funds, property or resources by another individual. Sadly, this exploitation is alive and well all year round.
6/14/2022
Since the initial roll-out of ASU 2016-13, Financial Instruments—Credit Losses (Topic 326), much of the prevailing focus has been on accounting for expected credit losses in loan portfolios. As the CECL implementation date draws near for nonpublic business entities, we are starting to receive new questions about CECL’s impacts to securities portfolios as well.
6/13/2022
Nacha’s Supplementing Data Security Requirements rule expands the existing ACH Security Framework to explicitly require large, non-financial institution Originators, Third-Party Service Providers and Third-Party Senders to protect account numbers (consumer and non-consumer) used in the initiation of ACH entries by rendering them unreadable when stored electronically.
6/2/2022
Keeping your ACH clients informed is critical. In this webinar Senior Consultant Janice Weisz, AAP, will discuss the importance of educating ACH clients and will share tools and best practices to keep ACH clients informed of Nacha Rules and originator responsibilities.
6/1/2022
Following the Florida Bankers Association’s annual CFO Symposium, the Saltmarsh Bank Advisors will be hosting a short update to recap hot topics including an industry overview, M&A, balance sheet strategies, ALM and more.
5/31/2022
As of May 1, 2022, banks must now notify their primary federal regulator within 36 hours of determining a "notification incident" has occurred, while a bank service provider is required to notify each affected bank "as soon as possible" if an incident is "reasonably likely" to cause a disruption for more than four hours.
5/3/2022
The latest issue of the FDIC’s Consumer Compliance Supervisory Highlights details issues identified during the agency’s approximately 1,000 exams completed in 2021. It includes aggregate citations as they relate to Level 3 and Level 2 violations. Level 3 violations present the very highest level of concern and may well lead to formal enforcement actions. The most frequently cited violations, listed below, represent 78% of the total violations cited.
4/27/2022
As the number of states with legalized marijuana or USDA-approved hemp programs increase, so does interest and concern around providing financial services to the industry.
4/13/2022
Over the last three months, unrealized losses in available-for-sale (AFS) securities portfolios have accelerated at a staggering rate.
3/11/2022
Nacha’s WEB Debit Account Validation Rule requires ACH originators of WEB debit entries to implement a commercially reasonable method to determine that the account number to be used for a WEB debit entry is for a valid account. This means the account to be debited is a legitimate, open account to which ACH entries may be posted at the receiving depository financial institution. The requirement applies to the first use of an account number or changes to the account number.
2/25/2022
Webinar recording. Bank insurance renewals have become anything but routine. Dennis Gustafson from AHT Insurance joins us for a webinar on the metrics behind financial institutions’ insurance; and review trends in the D&O claims environment and how they are moving the market.
2/22/2022
Nacha Rules state that ODFI’s are responsible for all entries originated through the ACH Network using the ODFI’s routing number and that ODFI’s are responsible for their ACH clients' compliance with the Nacha Rules. In addition, because the payments industry is constantly evolving, ODFI’s need to keep their ACH clients informed of Nacha Rule changes. Therefore, ODFI’s should have a formalized process to keep their ACH clients informed of Nacha Rules and originator responsibilities.
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