Matthew Schmitzer

Each phase of a company’s Part 370 response will have to undergo rigorous testing to ensure that all the regulatory requirements are met and the FDIC’s ongoing testing will produce satisfactory results. Our industry-leading DevOps organization that can assist with: Test planning and execution Defect tracking and reporting Requirements traceability Continuous integration As with requirements […]

For each of the technical work streams involved in a company’s Part 370 response, requirements will need to be defined and vetted with key stakeholders across the organization, as well as potentially with regulators. We have extensive experience creating business, functional, and technical requirements across a number of different companies in the financial services space. […]

A bank’s response to Part 370 will require a multi-year, multi-functional program that could encompass dozens of individual projects. Given the scope and scale of affected institutions, most will already have several layers of project management responsible for different areas of the business. A strong response to Part 370 will need to integrate those different […]

In order to support the initial and ongoing response to Part 370, most organizations will need to implement new processes around data and account management, reporting, and file generation. While each of these process updates can happen individually under those projects, it would be beneficial for a company to take a holistic approach to process […]

Part 370 requires two annual reports to be generated by covered institutions, and while the general requirements for each are laid out in the rule, there is little specificity about how the reports must be structured or formatted. We have experience designing reports to accommodate banking regulators and is positioned to help a company design […]

The FDIC requires a set of four files to be available within 24 hours of a bank’s failure, and responding companies must design how these files will be generated, stored, and transmitted. Having the data available to respond is a critical first step, but thought must put into how the company will actually take that […]

Evaluating where a bank stands today and where it needs to be in relation to Part 370 is of paramount importance in the early phase of the company’s response to the FDIC. Putting together a coherent road map that lays out concrete projects to be undertaken will allow the company to mount a coordinated response […]

The first thing any bank has to do in its response to Part 370 is evaluate its current state of readiness. We are well positioned to help firms assess readiness along a number of dimensions: Data availability and reliability Systems architecture Infrastructure Organizational structure We have helped dozens of organizations, both within financial services and […]

The basis for any response to Part 370 will be a thorough analysis of customer, account, and deposit data across the organization. This can be a massive undertaking at an organization the size of those targeted by Part 370. We have led dozens of data analysis and remediation efforts across industries, including: System identification: Looking […]

In order to comply with FDIC Part 370, covered institutions will have to implement a change program that encompasses the people, processes, and technology necessary to support on-site FDIC inspections. In addition to the annual certification and report, the FDIC will conduct on-site testing of institutions’ compliance with Part 370. While it has not defined […]

In order to comply with FDIC Part 370, covered institutions will have to implement a change program that encompasses the people, processes, and technology necessary to implement FDIC-required calculations and reports. Once an organization has determined that it is able to meet the requirements of Part 370, it must go about designing their interfaces with […]

In order to comply with FDIC Part 370, covered institutions will have to implement a change program that encompasses the people, processes, and technology necessary to manage customer access to funds. In the event of a failure, the bank’s systems must be able to apply provisional holds on deposit accounts to allow the FDIC to […]