• NAIC’s ORSA subgroup provides new feedback to the industry

    The NAIC formally adopted the Own Risk and Solvency Assessment (ORSA) Model Act in September 2012, and the ORSA requirement for qualifying insurers will be effective January 2015. In an effort to improve guidance and regulation, the NAIC’s ORSA (E) Subgroup has completed two feedback pilot projects, one in June 2012 and the most recent in September 2013.
  • Insider loan fraud: Regulation O violations

    Is your financial institution Regulation O compliant? How transparent are transactions among insiders of your financial institution? Insider abuse can be difficult to detect and cannot only lead to substantial FDIC penalties but will increase the reputation risk of your financial institution.
  • Devising Plan B: What to do when (and before) disaster strikes

    Too many banks prepare a business continuity/disaster recovery plan that collects dust on a shelf or ignores critical components. Plans aren’t tested or updated. They fail to plan for certain contingencies, such as a CEO who’s unavailable when disaster strikes. Federal and state agencies require a written business continuity and disaster recover plan. Smart business requires something more: a thorough plan that takes every contingency into account and is tested and updated regularly.