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New Data Shows Why Consumers Change Banks

We know that banks and credit unions have long relied on inertia as one of the primary forces that kept consumers from switching. You literally had to be driven away by horrible service or high fees – it was just way too much of a hassle to change accounts, get new checks and set up […]

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FDIC Part 370 Testing Support

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 […]

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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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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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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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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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FDIC Part 370: Identify Data Sources And Remediate 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 identify data sources and remediate data. For the largest and most complex depository institutions, account and customer data can be spread across dozens or even hundreds of backend systems. […]

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What FDIC Part 370 Means For Large Banks

Currently, the FDIC estimates that the 38 largest banks will fall under the rule’s provisions. Those banks have until April 1, 2020 to either be in compliance or have secured any relevant exceptions or exemptions. In order to be in compliance, covered institutions will have to implement a change program that encompasses the people, processes, […]

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The 10 Parts Of FDIC Part 370

Part 370 is broken into 10 parts, as follows. 370.1 Purpose and scope The purpose of Part 370 is to improve the FDIC’s ability to fulfill its two mandates related to paying deposit insurance: Pay deposit insurance as soon as possible after the failure of a covered bank; and Resolve a covered institution with the […]

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FDIC Part 370: The Background

The financial crisis of 2008 brought several institutional collapses that were unanticipated in both scale and speed. While existing processes were deemed suitable to handle smaller or slower bank failures, the FDIC realized that it might struggle to pay depositors if a complicated bank failed rapidly. The FDIC is required by law to pay depositors […]

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[Guide] A Comprehensive Guide To FDIC Part 370

The Recordkeeping for Timely Deposit Insurance Determination rule, more commonly referred to as 12 CFR Part 370, or simply Part 370, became effective April 1, 2017. The rule details new recordkeeping and reporting requirements for the largest depository institutions that help ensure prompt payments to consumers in the event of institutional failures. Part 370 generally […]

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Report: Digital Transformation Is Key To Boosting Customer Satisfaction

The American Customer Satisfaction Index (ACSI), which measures the satisfaction of consumers with the quality of products and services offered by companies across a variety of industries, released a report that suggests digital transformation is helping financial services companies increase customer satisfaction. The ACSI report, which is based on 17,861 customer surveys collected between October […]

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