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Requirements Gathering For FDIC Part 370

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. […]

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DataStax Advanced Security : Eat your vegetables first

I see companies start down their Big Data/NoSQL journey with a Proof of Concept mindset and they almost always end up funding a science project by confusing early wins on established products with progress. Cassandra is ten years old and DataStax has 500 customers in 50 countries. This stuff works; what you need is a […]

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[Guide] 2018 State of the Insurance Industry

Creating value for customers, employees, partners, and shareholders has always been the core objective of insurance companies. Today, the only difference is that stakeholder expectations are evolving faster because of technical innovation. While expectations are increasing, it is becoming more challenging to establish and retain relationships, and grow at more profitable levels. Our new guide […]

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Solving the Multiemployer Pension Plan Crisis

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, […]

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FDIC Part 370 Program Management

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 […]

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Extreme Customer Experience Makeover

Digital innovation continues to disrupt industries at lightning speed. Today’s organizations are transforming their entire business – from strategy to operations, technology to culture – to better deliver value to their customers. In 2017, we compiled the top 10 trends leaders needed to know when it came to their digital transformation journey. In this 10-week […]

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Hardship Distribution Changes: Impact on Retirement Plan Sponsors

When it left the House of Representatives in December 2017, the Tax Reform and Jobs Act carried several changes to the limits that should be placed on hardship withdrawals. While those changes never made it to the final version, many of them are included in the Bipartisan Budget Act of 2018. These include: Plans may […]

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Process Reengineering For FDIC Part 370 Compliance

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 […]

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California Wildfires: Considerations for Retirement Plan Sponsors

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 […]

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FDIC Part 370 Report Design

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 […]

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File Generation For FDIC Part 370

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 […]

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FDIC Part 370 Implementation Road Map

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 […]

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FDIC Part 370 Readiness Evaluation

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 […]

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Data Stewardship For FDIC Part 370

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 […]

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FDIC Part 370: Support On-site FDIC Inspections

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 […]

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FDIC Part 370: Implement FDIC-Required Calculations And Reports

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 […]

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FDIC Part 370: Manage Customer Access To Funds

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 […]

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FDIC Part 370: Manage And Maintain Customer And Deposit Data

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 and maintain customer and deposit data. Once a bank has identified existing customer and deposit data and laid out a plan for remediating deficiencies, it must define a […]

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Can A Fiduciary Determine If A Fund Is TOO Cheap?

What happens when the unstoppable force of retirement services recordkeeping faces the immovable object of low-fee funds? We’ll probably have to wait for the courts to decide. Recently, Fidelity Investments, TD Ameritrade, and Morgan Stanley all announced that they will be charging additional fees to customers who invest in The Vanguard Group’s funds. While this […]

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