Regulatory Compliance

At the end of 2017, the Pension Benefit Guaranty Corporation (PBGC) estimated that multiemployer plans were underfunded by $65.1 billion, an increase of $6.3 billion from the end of 2016. The Budget Act of 2018 established the “Joint Select Committee on Solvency of Multiemployer Pension Plans.” This committee held its first meeting on March 14, […]

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 […]

The Bipartisan Budget Act of 2018 addresses relief for the California wildfires of 2017, including, but not limited to: “Qualified individuals” whose primary residences were in specific wildlife disaster zones between October 8 and December 31, 2017 have several new opportunities to access plan benefits that are not otherwise available, including not being hit with […]

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 […]

Connected medical devices promise value for patients and physicians, but the devices also present new cybersecurity exposures that could put patients and their information at risk. The ECRI Institute, known for evaluating medical device cybersecurity, has developed a list of 10 problems facing medical device cybersecurity. These 10 key issues have the potential to be […]

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 […]

There has been a lot of talk about the Bipartisan Budget Act of 2018, which was passed by Congress and signed by the President on February 9th, 2018. The law will last for two years and increase funding for both military and social programs. It represents the first significant bipartisan legislation in a long time. […]

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 […]