Integrated Deposit Origination

Transcription

1 Integrated Deposit Origination New Functionality and Best Practices Bill Johnson, Development Supervisor Adi Rebronja, ido Implementation May 25th, 2017

2 Agenda New functionality Masking of TIN and ID Numbers (UII) BizChex ID Authentication Deluxe Check Ordering FinCEN Beneficial Ownership Best practices Improving the ido Workflow Sales and Reporting 2

3 2017_01 Release Masking of TIN and ID Numbers (UII) Protection against undisclosed exposure of private customer information Encryption and masking of Uniquely Identifiable Information including: Social Security Number / Tax ID Number Identification Values for IDs (new controls at ID Type) for ID Types containing numbers: Driver s License Number Passport Number Military ID Number SSN/TIN will be converted to tokens displaying only the last four digits of the original value Original Value Masked TIN XXXXX6789 Your institution can view the TIN in the clear from RM if you have the authority Control at the document level whether the TIN (existing control) and ID number (new control) are printed on documents in the clear or masked 3

4 2017_01 Interim Release BizChex provided by ChexSystems New option on ido Credit and Decisioning Menu Verifies identity and performs a risk assessment on commercial and small business applicants Increase in profitability by reducing fraud and minimizing exposure through efficient real-time detection Mitigate risk and assign checking privileges while also evaluating the identity of the business With a single inquiry request, you get a comprehensive assessment on the business entity 4

5 2017_01 Interim Release ID Authentication provided by ChexSystems New option on ido Credit and Decisioning Menu Quickly authenticates identity prior to account opening Generates real time questions using personal background information known to applicant A Pass or Fail response will be provided immediately Reduces overall fraud losses Great new tool for banks using ido Session Manager for Call Center activities 5

6 2017_01 Interim Release Deluxe Check Order Interface Updates Integrating new authentication method that uses a token instead of a Deluxe Certificate, which has to be renewed every few years Deluxe interface will be updated to transmit additional information to Deluxe, including the customer s address and the user ID of the FI s representative that processed the request 6

7 FinCEN Beneficial Ownership Mandatory Compliance Effective Date: May 11, 2018 Beginning on the Compliance Effective Date, covered financial institutions must identify and verify the identity of the beneficial owners of all legal entity customers at the time a new account is opened (Deposits and Loans) The financial institution may comply either by Obtaining the required information on a standard certification form offered by WKFS and ido Or by any other means (i.e. electronically) that comply with the requirements The financial institution may rely on the beneficial ownership information supplied by the customer Has no knowledge to call into question the reliability of the information The identification and verification procedures for beneficial owners are very similar to those for individual customers under the existing customer identification program (CIP) For beneficial owners, the institution may rely on copies of identity documents Financial institutions are required to maintain records of the beneficial ownership information for each entity account Not just a one once and forget about it Certain accounts are exempt Listed in final ruling 7

8 FinCEN Beneficial Ownership New Requirements for Entity Accounts Identification Covered financial institutions are required to identify up to 4 (four) beneficial owner(s) 25% or more AND One controlling individual (always required) Verification can be conducted by documentary and/or non-documentary methods The account cannot be used until the verification process has been completed All of the identifying information for each of the beneficial owners must be retained for five years after the date the account is closed Develop a customer risk profile Requires that all covered financial institutions understand the nature and purpose of customer relationships necessary to develop a customer risk profile. Monitoring While there is no requirement that a financial institution obtain updated beneficial ownership information from its customers on a regular basis, it is expected that should a financial institution learn as a result of its normal monitoring that the beneficial owners of a legal entity customer may have changed, it should update the customer information accordingly. Including for those accounts existing on the Compliance Effective Date 8

9 FinCEN Beneficial Ownership Collecting Information For each individual, if any, who owns, directly or indirectly, 25 percent or more of the equity interests of the legal entity customer: First and last name Date of birth Address (residential or business street address) Taxpayer ID number (SSN for US person; passport number and country of issuance or similar ID number for foreign persons) AND for one individual with significant responsibility for managing the legal entity (Always required): Title (CEO, CFO, President, Vice President etc.) First and last name Date of birth Address (residential or business street address) Taxpayer ID number (SSN for US person; passport number and country of issuance or similar ID number for foreign persons) 9

10 FinCEN Beneficial Ownership Model Document Can be inserted into new account workflow WKFS will provide document for ido Will require each beneficial owner and controlling individual to be setup as customer records Establish new Relationship Types Beneficial owner Controlling individual Review availability with loan origination provider Not the only method for collecting required information 10

11 FinCEN Beneficial Ownership Customer-to-Customer Relations HORIZON will use Customer-to-Customer Relationships to relate Beneficial Owners and Entity Managers to the Entity Customer Why Customer-to-Customer? Avoids confusion of tellers Allows user to view total influences of a customer who has beneficial ownership of more than one entity Will ido workflow be enhanced to queue the user to obtain beneficial ownership? Yes, when a HORIZON non-personal customer is added to an ido account title, the user will be asked to verify if beneficial ownership information collection is necessary Response will be reported How will users document the evaluation activity? HORIZON customer and account notes may be used to document how information was collected. 11

12 FinCEN Beneficial Ownership Touchpoints Touchpoints for origination of legal entities: New account policies and procedures for legal entities Deposits and lending Training of staff Coordination with your compliance office Customer education Integrated Deposit Origination (ido) forms and workflow Loan origination forms and workflow HORIZON account title setup and maintenance HORIZON Relationship Types HORIZON RM account title setup and maintenance Integration to BSA/AML solutions 12

13 Best Practices Improving the ido Workflow Disclosure Defaults Can be set by products example: Personal DDA s, Business DDA s, etc. Improves efficiency Compliance Document Packages Required / Optional documents placement Document sections hyperlinks Documents based on product / relationship codes 13

14 Best Practices Improving the ido Workflow Account number generator Up to 10 digit account numbers Operation efficiencies avoids user errors Identify product type and branch where account opening occurred by account number format Generated account numbers maintained at account creation based on BCR s Operation efficiencies avoids user errors Potential cost reduction no orders from check vendors for starter kits 14

15 Best Practices Sales Linking / Recommending products Account packages (examples below) Advantage / Preferred account packages (revenue creation, increased balances, increased relationships) Direct Deposit account packages (Checking and Savings account with monthly auto transfer increasing savings balance) Complimentary products Debit card to DD accounts 15

16 Best Practices Training for Universal Service Representative Universal Service Representative Workshop This intensive training opportunity covers topics from identifying sales opportunities to building relationships and everything in between During the workshop, participants engage in hands-on activities and role-plays to strengthen key behaviors for improving conversations with clients Help your Financial Institution: Increase operational efficiency Improve your market position Increase revenue generation for more information 16

17 Best Practices Reports and Tracking Session Log Report Measure branch session activity users to utilize ido sessions during the day Time efficiency identify users spending more time on maintenance VS revenue generating New Account / Customer-Credit Verification Report Measure account creation activity (search by Branch or User) Month to Month reporting, annual reporting and activity Marketing / Promotional product activity Credit Verification Report Quickly accesses or searches QualiFile responses All of the session OFAC hits appear if OFAC Search Option is turned on in the BCR s 17

18 Questions? 18

19 Adi Rebronja and John Bonenberger ido Implementation Analysts