Now Onboarding All Rows and All Passengers for Flight WACHA 2014
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1 Now Onboarding All Rows and All Passengers for Flight WACHA 2014 Regulatory, Compliance, and On Boarding Best Practices Brent Siegel, CSOP, CRFS, MBA, Argos Risk Wendy Wishon, AAP, NCP, EPCOR March 18, 2014
2 a true story SO CUTE! SO INNOCENT! 9 year old boy
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6 HOW DID THIS HAPPEN? WHERE DID THE ONBOARDING PROCESS FAIL?
7 AGENDA
8 Improving the Onboarding Process 2014EPCOR EPCOR.. All All rights rights reserved.
9 FFIEC Retail Payment Examination Handbook EPCOR.. All All rights reserved. 9
10 OCC ACH Risk Management Guidance EPCOR. All rights reserved.
11 IRS EPCOR. All rights reserved.
12 OFAC EPCOR.. All All rights reserved. 12
13 BSA and OFAC EPCOR.. All All rights reserved. 13
14 Board Strategic Objectives Establish business strategy and risk parameters Oversee management s implementation of the program Develop strategic objectives, limitations, and overall risk appetite Approve ACH policies 2014 EPCOR. All rights reserved. 14
15 ACH Policy Territory Territory SEC Codes SEC Codes Originator Originator Types Types Collateral, Collateral, Funding Pre-Funding Approval Approval Requirements Requirements Exposure Exposure Limits Limits ACH Risk Management Committee Responsibilities Documentation Monitoring Procedures OFAC 2014 EPCOR. All rights reserved.
16 Due Diligence Underwriting Standards Formal review of all Originators Process to match level of risk 2014 EPCOR. All rights reserved.
17 Underwriting Underwriting Standards Define desirable, prohibited, and restricted originators Require a background check of the originator Require evaluation of the originator's creditworthiness Outline the type and timing of financial information to be provided by the originator 2014 EPCOR. All rights reserved.
18 Underwriting Underwriting Standards Require review of the originator's sales history Summarize documentation requirements List permissible Standard Entry Class (SEC) types Provide authorization procedures for approved originators 2014 EPCOR. All rights reserved.
19 Underwriting Underwriting Standards Provide guidelines for setting exposure limits, including requirements for pre-funding or collateral requirements Establish over limit monitoring and approval Outline originator account termination procedures Allow the institution to audit originators' ACH processes 2014 EPCOR. All rights reserved.
20 Unbiased Originator Info 2014 EPCOR. All rights Copyright 2014 EPCOR Allreserved. rights reserved. 20
21 Dun & Bradstreet Verify company legitimacy 2014 EPCOR.. All All rights reserved. 21
22 LexisNexis Verify company legitimacy 2014 EPCOR.. All All rights reserved. 22
23 Enhanced Due Diligence Third-Party Senders 2014EPCOR EPCOR.. All All rights rights reserved.
24 HOAs Homeowners Associations Property Rental Companies Difficult to identify parties involved & associated risks 2014 EPCOR. All rights reserved. 24
25 Third-Party Senders ODFI should know details Require TPSs to provide info Verify it s a legitimate business Request to see agreements 2014 EPCOR. All rights reserved. 25
26 Agreements Consider applicable regulations & laws 2014 EPCOR. All rights reserved. 26
27 5 ONBOARDING STEPS THAT LEAD TO BETTER RISK MANAGEMENT Underwrite Model Monitor Analyze Verify 27
28 ONBOARDING ACTIVITIES (1) KYC and KYCC (2) Modeling ACH Risk Monitoring Business Activities (3) and Transactions
29 ONBOARDING ACTIVITIES (1) KYC and KYCC Gather Data Score Risk Compare Business Type (2) Modeling ACH Risk Type Value Frequency Compare (3) Monitoring Business Activities and Transactions Business Activities Outside the Firewall Inside the Firewall Respond to Changes Limit Setting
30 ONBOARDING ACTIVITIES (1) KYC and KYCC Gather Data Score Risk Compare Business Type Know Your Customer KYC Require background check get a Credit Report Validate legitimacy of the business If necessary, supplement with background check on the principal business owners Consistency of data acquired 3 rd party senders KYC and KYCC Due diligence on the Third Party Senders Due diligence on the customers of the Third Party Senders Validating limits plus identifying and evaluating risk
31 ONBOARDING ACTIVITIES (1) Validate the firm find external data KYC and KYCC Gather Data Score Risk Compare Business Type Examine the data intrinsic risk, extrinsic risk Compare the data and the customer to your existing customers Establish a base line of data and monitor changes Establish a reaction plan if new results are negative Build an automated master calendar for reviews, notices, and renewal dates for each firm
32 ONBOARDING ACTIVITIES (1) KYC and KYCC Gather Data Score Risk Compare Business Type Evaluation Totals Total Argos Risk Accounts 1057 Account highlights: Foreclosed properties new owners 3 Inactive corp 4 Bankrupt Company 1 Money Service Businesses 1 Need additional info 70 Residential address 9 Unable to find 78 UPS PO Box 3 Total 166
33 ONBOARDING ACTIVITIES (1) KYC and KYCC Gather Data Score Risk Compare Business Type
34 ONBOARDING ACTIVITIES (1) KYC and KYCC Gather Data Score Risk Compare Business Type
35 ONBOARDING ACTIVITIES (1) KYC and KYCC ODFI THIRD PARTY SENDER PORTFOLIO Gather Data TPS #1 TPS #2 TPS #3 TPS #4 Score Risk Compare Customer 1 Customer 1 Customer 1 Customer 2 Customer 2 Customer 2 MSB MSB Customer 3 Customer 3 Customer 3 Customer 1 MSB Customer 2 Customer 3 Customer 4 Customer 4 Customer 4 Business Type Customer 5 Customer 5
36 ONBOARDING ACTIVITIES (1) KYC and KYCC Gather Data Score Risk Compare Business Type
37 ONBOARDING ACTIVITIES (1) Do you have a list of businesses that KYC and KYCC Gather Data Score Risk Compare Business Type you list as high risk or that you do not want to work with? TOD Terminated originator database Restricted types or industries? Travel Agencies Grocery Stores Fritz s Pub? 24 MSB s within 5 minutes of here 321 MSB s in Wisconsin
38 Terminated Originator Database EPCOR.. All All rights reserved. 38
39 ONBOARDING ACTIVITIES (1) KYC and KYCC Gather Data Score Risk Compare Business Type Restricted Types: Adult Sites (including Adult Novelties) Internet Casinos or Gambling of Any Kind, Including Odds Making Escort Services Out bound Telemarketing Fortune Tellers Collection Agencies / Debt Refinancing / Credit Restoration Pyramid Sales "Get Rich" or "Life Coach" Programs, Books, DVD's Sending of Money/Cash Advances Sale of Stocks, Securities, Options and Other Investments Merchant Account Factoring accepting payment for products you do not own Alcohol, Firearms, Tobacco Products & Drugs and Drug Paraphernalia Goods/Services prohibited by law or card associations
40 ONBOARDING ACTIVITIES (1) KYC and KYCC Gather Data Score Risk Compare Business Type (2) Modeling ACH Risk Type Value Frequency Compare (3) Monitoring Business Activities and Transactions Business Activities Outside the Firewall Inside the Firewall Respond to Changes Limit Setting
41 ONBOARDING ACTIVITIES (2) Modeling ACH Risk Type Value Frequency Compare Limit Setting
42 ONBOARDING ACTIVITIES (2) Modeling ACH Risk Type Value Frequency Compare Limit Setting
43 ONBOARDING ACTIVITIES (2) Modeling ACH Risk Type Value Frequency Compare Limit Setting
44 ONBOARDING ACTIVITIES (1) (2) Onboarding: KYC Modeling and KYCC ACH Risk Gather TypeData Score Value Risk Frequency Compare Business Compare Type (3) Monitoring Business Activities and Transactions Business Activities Outside the Firewall Inside the Firewall Respond to Changes Limit Setting
45 ONBOARDING ACTIVITIES (1) KYC and KYCC Gather Data Score Risk Compare Business Type (2) Modeling ACH Risk Type Value Frequency Compare (3) Monitoring Business Activities and Transactions Business Activities Outside the Firewall Inside the Firewall Respond to Changes Limit Setting
46 ONBOARDING ACTIVITIES (3) Monitoring Business Activities and Transactions Business Activities Argos Risk is OUTSIDE Systems Vendors that are INSIDE PPD Outside the Firewall Inside the Firewall Respond to Changes FIREWALL CCD RDC
47 ONBOARDING ACTIVITIES (3) Monitoring Business Activities and Transactions Business Activities Outside the Firewall Inside the Firewall Credit Score Years in Business Employees Payment Records Past Due Records Vendor Payment Volatility Amount of Legal Process Days Beyond Terms Percentage of Slow Pays Trade References Business Health Timely Payments High Credit Offered Multiple Trade References Lawsuits, Liens, Litigation Poor Industry trends Challenging Geography Declining Business Scores Payment Consistency Timely Payments Increased Credit Offered Trade References Low Past Dues Legal Process Filings Days Beyond Terms More Slow Payments Fewer Trade References Terms Consistency Payment Trends Increased Credit offered More References Fewer Past Dues Slow Payments Increased slow or negative payment activity Fewer Trade References ACH Risk Origination volume Frequency SEC type SEC Return Rates Industry Risk Class Temporal Risk Multiple Settlements ACH Risk Index Average Volume Peak Risk Respond to Changes
48 (3) Monitoring Business Activities and Transactions Business Activities ONBOARDING ACTIVITIES Business Name ACH Customer Profile Data Input 2 ACH Transaction Data Input 3 Outside the Firewall Input 1 Inside the Firewall Respond to Changes
49 ONBOARDING ACTIVITIES (3) Monitoring Business Activities and Transactions Business Activities Outside the Firewall Inside the Firewall Respond to Changes Actionable alerts: delivery at 6:00 AM CT Internal alerts Material change in scoring metrics External alerts: Slow paying vendors Lawsuits and liens Delayed or inaccurate financial reporting Changes in key personnel Mergers and acquisition information MSB authorizations Material negative event (ie: data breach incident)
50 ONBOARDING ACTIVITIES (3) Monitoring Business Activities and Transactions Business Activities Outside the Firewall Inside the Firewall Respond to Changes
51 ONBOARDING ACTIVITIES (3) Monitoring Business Activities and Transactions Business Activities Outside the Firewall Respond to changes! Lawsuit response? Executive change response? Risk profile changes? Bankruptcy? What have you planned as a response? Inside the Firewall Respond to Changes
52 CONTACT THE PRESENTERS Brent Siegel Argos Risk Wendy Wishon, AAP, NCP EPCOR
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