Category Archives: Uncategorized

Business Continuity and Disaster Recovery

Tornado Virtual Tabletop Exercise

disasterFEMA’s Emergency Management Institute Virtual Tabletop Exercise program will offer six sessions of a tornado scenario on March 7, 8, and 9 from 12-4 p.m. ET. Content is the same each day, and participants would attend only one session in February or March. The application deadlines for these exercises is Jan. 25.

The VTTX involves key personnel discussing simulated scenarios in an informal setting and can be used to assess plans, policies, training, and procedures. The design of the VTTX is for a group of ten or more representatives from state, local, tribal, and territorial emergency communities of practice and is intended to provide an opportunity for responders across the nation to simultaneously participate in a hazard-specific facilitated discussion. Participants will need to connect via a site equipped with the appropriate VTC capability (not Adobe Connect or FaceTime-based), but alternate ways to participate are also available upon request.

To participate, send an email to Doug Kahn at douglas.kahn@fema.dhs.gov or call 301-447-7645. Also, send a courtesy copy email to the Integrated Emergency Management Branch at fema-emi-iemb@fema.dhs.govor call 301-447-1381. Additional information is available at https://training.fema.gov/programs/emivttx.aspx.

Keep secure with a culture of security

sbsLearn more about how to improve security at your bank with Secure Banking Solution‘s tips for creating a culture of security. Their blog explores some tips about how to test staff, set up expectations, and how to promote positive actions. Click here to find out more.

Money Smart Small Businesses

moneysmartThe Federal Deposit Insurance Corporation (FDIC) and the U.S. Small Business Administration (SBA) have released enhancements to Money Smart for Small Business, a resource that provides practical guidance for starting and managing a small business.

Money Smart for Small Business, a free curriculum available on the FDIC website, was jointly developed by the FDIC and SBA in 2012. Three new modules have been added, focusing on managing cash flow, planning for a healthy business and helping learners to determine if owning a business is a good fit. The curriculum, which now includes 13 modules, is available for download in both English and Spanish. In addition, a Train-the-Trainer curriculum was created to help organizations train instructors to deliver the modules. Training modules can be taught in any order or independently and typically run 60–90 minutes. Each module, and the Train-the-Trainer curriculum, includes a fully scripted instructor guide, participant workbook and PowerPoint slides that can be edited to meet the needs of any audience. These features and flexibility make Money Smart for Small Business a valuable resource for entrepreneurs.

Review FDIC Money Small Businesses here.

Review SBA Money Small Businesses here.

Revised FLSA & EPPA Posters

sourcing-and-vendor-managementThe U.S. Department of Labor (DOL) has updated their mandatory posters which notify employees of their rights under the Fair Labor Standards Act (FLSA) and the Employee Polygraph Protection Act (EPPA). The new posters were effective August 1, 2016.

To avoid possible penalties, banks should promptly update their federal labor law posters for the Fair Labor Standards Act and the Employee Polygraph Protection Act. The maximum penalty for poster violations has increased to $525. Copies of the revised FLSA and EPPA posters may be downloaded directly from the DOL’s website.

Download the FLSA poster.

Download the EPPA poster.

Guidance on Military Lending Act

mlaOn August 26, 2016, the Department of Defense issued an Interpretive Rule to help clarify questions regarding the amended Military Lending Act (MLA). The amended rules take effect on October 3, 2016 – just three short weeks away! The MLA, as implemented by the Department, limits the military annual percentage rate (MAPR) that a creditor may charge to a maximum of 36 percent, requires certain disclosures and provides other substantive consumer protections on “consumer credit” extended to Service members and their families.

The Interpretive Rule provides clarification in the form of a Q & A regarding the following topics:

  • If hybrid purchase money loans fall within the exception to “consumer credit” under the rule
  • The timing of fee waivers/reductions when fees cause the MAPR to exceed 36 percent
  • If assignees receive the same safe harbor protections as the initial creditor
  • How to perform periodic post-closing screening of covered borrowers for open-end credit and not violate the historic lookback prohibition
  • How to meet the requirement to provide disclosures orally
  • If a single credit agreement may be used for loans covered and not covered by the MLA
  • If a creditor may accept a check or set up an auto debit for loans subject to the MLA (and what is still prohibited)
  • Whether a creditor may accept deposit accounts as collateral for loans to a covered borrower
  • If right of offset can be applied to a loan subject to the MLA
  • Other details affecting credit card products

To review the Interpretive Rule, click here.

REMINDER – ALL banks are subject to this amended rule! Are you ready??

If the rules have your head spinning and you still aren’t sure if your bank will be subject to the amended MLA rules, we want to remind you of the two part MLA webinar series available from the IBA. Part 1 covers what loans were covered, the definition of a covered borrower, safe harbor protections, MAPR calculations, disclosure requirements and contract prohibitions and was presented on May 18. This session was recorded and still available on-demand. Part 2 will be presented September 14 at 10 a.m. This session will provide a recap of the rule changes, a detailed review of the Interpretive Rule and an overview of the credit card rules that go into effect in 2017. Don’t miss out! Purchase Part 1 and register for Part 2 today by clicking here!

CFPB Releases Consumer Resources and Guide on Auto Loans

auto loan.jpgThe Consumer Financial Protection Bureau (CFPB) released an auto loan shopping sheet, a step-by-step guide, and additional online resources as part of the Know Before You Owe initiative.

The auto loan shopping sheet will help consumers see the total cost of a loan, and make comparisons among loan products. The step-by-step guide will help consumers budget for the auto loan, understand auto financing choices, how to shop for an auto loan, how to negotiate the loan, and close the deal. The online resources and guide give consumers helpful tips so they can better negotiate the best deal possible.

The CFPB also released Consumer Voices on Automobile Financing, a report which analyzed how consumers approached their auto financing decision and challenges faced during the process.

Private Student Lending Guidance

moneyThe Office of Comptroller of the Currency (OCC) added a new booklet on private student lending to its Comptroller’s Handbook. The booklet provides examples of acceptable practices and policies for banks engaging in private educational lending, including in-school deferment; providing a six-month grace and extended grace periods immediately after graduation or withdrawal from school; and loan modifications for long-term hardships.

The booklet also highlights the differences between federal and private student loans and includes guidance for examiners on assessing the risks associated with private student lending. Read the booklet here.