Bennett Quillen's Blog

Information and Technology Services Professional

Month: March, 2013

Bennett Quillen – Bank Secrecy Lookback Guidelines

Lookback Guidelines

Background: Lookback covers the period mm/dd/yyyy through mm/dd/yyyy. The inventory of accounts to be reviewed is TBD. We will review 100% of HIGH, 50% of Medium and a statistical sampling of the LOW.

Currently we have about nnn accounts rated HIGH (business and retail). All other risk ratings in the ITI system are suspect. Therefore the Bank is doing a Risk Rating Form for each business transaction account. That is in process. (See the risk rating tool included as a separate doc). This is the rating we will use to identify the number of HIGH, MEDIUM and LOW risk accounts. In addition we will review Cash transaction from Patriot Officer (PO) and wire transfers to identify any other accounts that appear to need review and include them if they are not already included.

1) The risk rating sheet is the primary sheet. No file can be counted unless this is completed. It must be completed by the Bank as part of the Lookback is to validate the quality of the risk rating process. So any changes we recommend, whether raise or lower must be noted. When a consultant takes a risk rating sheet they are responsible for the entire relationship, as shown on the Portfolio printout from ITI.
2) We may need to adjust the Account review Cover Sheet as well as the Lookback Spreadsheet, as we should have better data from patriot Officer on Cash transactions. A report for each account can be generated which shows all cash transactions.
3) We will still need to test some deposits and obtain documentation in order to validate that deposits with cash show the cash in PO, and deposits with no cash show there is no transaction in PO.
4) CTRs should be sampled as deemed appropriate. Be aware of days with multiple transactions and test more of those. Check against the CT filed report. Also test by getting a copy of the CTR as some may be more complex with multiple parties. The number of CTRs tested per account should be tracked and any exceptions noted.
5) Each account review must identify who prepared it and it must be reviewed by another consultant. Any suspicious activity identified must be referred to the managing consultant or the Director.
6) These are guidelines and likely will need to be modified as we progress. Our day-to day contact will be the BSA Officer.

Bennet B Quillen – Fraud Forensics: Lookback Guidelines

Lookback Guidelines

Background: Lookback covers the period mm/dd/yyyy through mm/dd/yyyy. The inventory of accounts to be reviewed is TBD. We will review 100% of HIGH, 50% of Medium and a statistical sampling of the LOW.

Currently we have about nnn accounts rated HIGH (business and retail). All other risk ratings in the ITI system are suspect. Therefore the Bank is doing a Risk Rating Form for each business transaction account. That is in process. (See the risk rating tool included as a separate doc). This is the rating we will use to identify the number of HIGH, MEDIUM and LOW risk accounts. In addition we will review Cash transaction from Patriot Officer (PO) and wire transfers to identify any other accounts that appear to need review and include them if they are not already included.

1) The risk rating sheet is the primary sheet. No file can be counted unless this is completed. It must be completed by the Bank as part of the Lookback is to validate the quality of the risk rating process. So any changes we recommend, whether raise or lower must be noted. When a consultant takes a risk rating sheet they are responsible for the entire relationship, as shown on the Portfolio printout from ITI.
2) We may need to adjust the Account review Cover Sheet as well as the Lookback Spreadsheet, as we should have better data from patriot Officer on Cash transactions. A report for each account can be generated which shows all cash transactions.
3) We will still need to test some deposits and obtain documentation in order to validate that deposits with cash show the cash in PO, and deposits with no cash show there is no transaction in PO.
4) CTRs should be sampled as deemed appropriate. Be aware of days with multiple transactions and test more of those. Check against the CT filed report. Also test by getting a copy of the CTR as some may be more complex with multiple parties. The number of CTRs tested per account should be tracked and any exceptions noted.
5) Each account review must identify who prepared it and it must be reviewed by another consultant. Any suspicious activity identified must be referred to the managing consultant or the Director.
6) These are guidelines and likely will need to be modified as we progress. Our day-to day contact will be the BSA Officer.

Bennett B Quillen – Basel III Measurements

Basel III common equity and tier 1 capital changes
Summary of Basel III changes
• Minimum common equity requirement 2 to 4.5%
• Capital conservation buffer 2.5% – met with common equity. If under, greater contraints on earning distributions are imposed
• Total common equity requirement is 7%
• Higher capital requirements for trading, derivatives, securitisation at end 2011
• Tier 1 capital from 4 to 6% over the same period
• Countercyclical buffer in the range of 0 to 2.5% of common equity according to national circumstances
• Supplemented by non risk based leverage ratio
• Pillar 1 treatment will start on the 1st January 2018
Systemically important banks should have a loss absorbing capacity beyond the standards above. Such guidelines are being developed which could include capital surcharge, contingent capital and bail in debt.
Note: Large banks need a significant amount of additional capital

Facilitating “sound practices” in risk management with IBM® OpenPages® Operational Risk Management
Executive summary
This whitepaper discusses operational risk management in the context of “Sound Practices for the Management and Supervision of Operational Risk,” a paper from the Basel Committee that provides an outline for building an effective ORM framework to deliver a better return on investment and improved business performance.
Risk management in the current post-meltdown economy is perhaps the single largest challenge organizations are facing in today’s troubled corporate climate. The events of the last few years have prompted executives to focus their operational sights on risk management and take measures to evaluate how a well-defined risk strategy can drive business performance, even in the most perilous economic environment.
Factors such as increased transaction volumes, dependence on new technologies, the internet and mergers and acquisitions have introduced higher degrees of complexity and uncertainty in business operations.
In addition, rising shareholder influence and the recent high-profile financial fiascos resulting from the financial meltdown have led to increased regulation and anticipated legislation to ensure that risks are being managed in a more effective and auditable fashion.
As a result, organizations’ boards of directors now assume a greater degree of accountability and have begun to fully understand the importance of instilling a risk-aware culture to gain better visibility of corporate risk. To achieve these goals, organizations need to foster a risk-based approach to enterprise governance, where all employees view risk management as an integral part of their daily responsibilities. Whether employees are IT, audit, compliance or business line managers, there is always a risk of non-compliance risk of IT security or regulatory non-compliance, operational risk and so on. To be effective, a risk-based strategy requires cross-departmental collaboration and coordination to create a common language for risk and synchronize the activities of the different operational functions.
Contents:
1 Executive summary
2 The importance of risk management
2 The need for sound business practices
2 The Ability to Enforce Sound Practices
3 Principle I: Board approval
3 Principle II: Independent internal audit
3 Principle III: Senior management implementation
4 Principle IV: Risk identification and assessment
4 Principle V: Risk monitoring and reporting
5 Principle VI: Risk mitigation
5 Principle VII: Contingency and continuity Planning
5 Principle VIII: Supervisors requirement
5 Principle IX: Supervisors requirement
5 Principle X: Disclosure
6 Conclusion6 About IBM Business Analytics

Bennett Quillen – Basel III Measurements

Basel III common equity and tier 1 capital changes
Summary of Basel III changes
• Minimum common equity requirement 2 to 4.5%
• Capital conservation buffer 2.5% – met with common equity. If under, greater contraints on earning distributions are imposed
• Total common equity requirement is 7%
• Higher capital requirements for trading, derivatives, securitisation at end 2011
• Tier 1 capital from 4 to 6% over the same period
• Countercyclical buffer in the range of 0 to 2.5% of common equity according to national circumstances
• Supplemented by non risk based leverage ratio
• Pillar 1 treatment will start on the 1st January 2018
Systemically important banks should have a loss absorbing capacity beyond the standards above. Such guidelines are being developed which could include capital surcharge, contingent capital and bail in debt.
Note: Large banks need a significant amount of additional capital

Facilitating “sound practices” in risk management with IBM® OpenPages® Operational Risk Management
Executive summary
This whitepaper discusses operational risk management in the context of “Sound Practices for the Management and Supervision of Operational Risk,” a paper from the Basel Committee that provides an outline for building an effective ORM framework to deliver a better return on investment and improved business performance.
Risk management in the current post-meltdown economy is perhaps the single largest challenge organizations are facing in today’s troubled corporate climate. The events of the last few years have prompted executives to focus their operational sights on risk management and take measures to evaluate how a well-defined risk strategy can drive business performance, even in the most perilous economic environment.
Factors such as increased transaction volumes, dependence on new technologies, the internet and mergers and acquisitions have introduced higher degrees of complexity and uncertainty in business operations.
In addition, rising shareholder influence and the recent high-profile financial fiascos resulting from the financial meltdown have led to increased regulation and anticipated legislation to ensure that risks are being managed in a more effective and auditable fashion.
As a result, organizations’ boards of directors now assume a greater degree of accountability and have begun to fully understand the importance of instilling a risk-aware culture to gain better visibility of corporate risk. To achieve these goals, organizations need to foster a risk-based approach to enterprise governance, where all employees view risk management as an integral part of their daily responsibilities. Whether employees are IT, audit, compliance or business line managers, there is always a risk of non-compliance risk of IT security or regulatory non-compliance, operational risk and so on. To be effective, a risk-based strategy requires cross-departmental collaboration and coordination to create a common language for risk and synchronize the activities of the different operational functions.
Contents:
1 Executive summary
2 The importance of risk management
2 The need for sound business practices
2 The Ability to Enforce Sound Practices
3 Principle I: Board approval
3 Principle II: Independent internal audit
3 Principle III: Senior management implementation
4 Principle IV: Risk identification and assessment
4 Principle V: Risk monitoring and reporting
5 Principle VI: Risk mitigation
5 Principle VII: Contingency and continuity Planning
5 Principle VIII: Supervisors requirement
5 Principle IX: Supervisors requirement
5 Principle X: Disclosure
6 Conclusion6 About IBM Business Analytics

Bennett B Quillen – Threat Issues

Business destroyed at Operations Center resulting in loss of Divisions / Departments
Continuity Resulting in loss of IT services ability to conduct business
Planning to the entire organization
Guide
Plan needed Plan needed
Wealth Management How would the department How would the business unit communicate
Group process work “offline” in the with employees? How is non electronic
first 24 – 48 hours? data stored to ensure recovery?
How would the department How would the business unit communicate
Loan Operations process work “offline” in the with employees? How is non electronic
first 24 – 48 hours? data stored to ensure recovery?
How would the department How would the business unit communicate
Bookkeeping / process work “offline” in the with employees? How is non electronic
Deposit Operations first 24 – 48 hours? data stored to ensure recovery?
How would the department How would the business unit communicate
Control process work “offline” in the with employees? How is non electronic
first 24 – 48 hours? data stored to ensure recovery?
How would the department How would the business unit communicate
process work “offline” in the with employees? How is non electronic
Branches first 24 – 48 hours? data stored to ensure recovery? How
would safe deposit issues be handled?
Describe How the communications
hub would be reestablished at the
Operations Center? How would communications and network
IT Network Services equipment be replaced and restored at the
Describe process to replace/restore relocation site?
Network / IT equipment
How would the mainframe
Data processing services be restored offsite?
How would Facilities help Where would employees be relocated?
Facilities IT / DP in their How would space and equipment needs
Recovery efforts? be handled?

Bennett B Quillen – BCP Issues

Business destroyed at Operations Center resulting in loss of Divisions / Departments
Continuity Resulting in loss of IT services ability to conduct business
Planning to the entire organization
Guide
Plan needed Plan needed
Wealth Management How would the department How would the business unit communicate
Group process work “offline” in the with employees? How is non electronic
first 24 – 48 hours? data stored to ensure recovery?
How would the department How would the business unit communicate
Loan Operations process work “offline” in the with employees? How is non electronic
first 24 – 48 hours? data stored to ensure recovery?
How would the department How would the business unit communicate
Bookkeeping / process work “offline” in the with employees? How is non electronic
Deposit Operations first 24 – 48 hours? data stored to ensure recovery?
How would the department How would the business unit communicate
Control process work “offline” in the with employees? How is non electronic
first 24 – 48 hours? data stored to ensure recovery?
How would the department How would the business unit communicate
process work “offline” in the with employees? How is non electronic
Branches first 24 – 48 hours? data stored to ensure recovery? How
would safe deposit issues be handled?
Describe How the communications
hub would be reestablished at the
Operations Center? How would communications and network
IT Network Services equipment be replaced and restored at the
Describe process to replace/restore relocation site?
Network / IT equipment
How would the mainframe
Data processing services be restored offsite?
How would Facilities help Where would employees be relocated?
Facilities IT / DP in their How would space and equipment needs
Recovery efforts? be handled?

Bennett Quillen – Threat Assesment Issues

Business destroyed at Operations Center resulting in loss of Divisions / Departments
Continuity Resulting in loss of IT services ability to conduct business
Planning to the entire organization
Guide
Plan needed Plan needed
Wealth Management How would the department How would the business unit communicate
Group process work “offline” in the with employees? How is non electronic
first 24 – 48 hours? data stored to ensure recovery?
How would the department How would the business unit communicate
Loan Operations process work “offline” in the with employees? How is non electronic
first 24 – 48 hours? data stored to ensure recovery?
How would the department How would the business unit communicate
Bookkeeping / process work “offline” in the with employees? How is non electronic
Deposit Operations first 24 – 48 hours? data stored to ensure recovery?
How would the department How would the business unit communicate
Control process work “offline” in the with employees? How is non electronic
first 24 – 48 hours? data stored to ensure recovery?
How would the department How would the business unit communicate
process work “offline” in the with employees? How is non electronic
Branches first 24 – 48 hours? data stored to ensure recovery? How
would safe deposit issues be handled?
Describe How the communications
hub would be reestablished at the
Operations Center? How would communications and network
IT Network Services equipment be replaced and restored at the
Describe process to replace/restore relocation site?
Network / IT equipment
How would the mainframe
Data processing services be restored offsite?
How would Facilities help Where would employees be relocated?
Facilities IT / DP in their How would space and equipment needs
Recovery efforts? be handled?

Bennett B Quillen: English Rehab

Bennett Quillen is the founder and president of the English Rehabilitation Institute (ERI). Its purpose is to stem and reverse the current negative trend in the misuse and abuse of the English language in business. Today’s business is fraught with the contagion of abusive English practices e.g. twisting verbs into nouns and producing meaningless, even potentially damaging, words. ERI rehabilitates its students to become confident, productive users of the English language, thus benefiting themselves, their associates and their employers.

Bennett possesses over 35 years of broad experience in delivering speeches, conducting seminars and writing proposals and reports for companies, colleges and universities, and not-for-profit institutions. . He held a variety of senior executive and program management roles in operations and information technology. His consulting activities include companies throughout North America, Europe and the Middle East.

One of the keys to his success is the correct application and usage of the English language. His knowledge of the correct application of grammar and vocabulary has earned him the distinctive title of “Grammar Guru”. His success in business is directly dependent upon adopting correct terminology for the task at hand and avoiding sloppy, meaningless clichés.

To this end, Bennett Quillen founded the English Rehabilitation Institute (ERI), LLC. Today’s business is beset by the constant misuse, or downright corruption, of words. When meaningless or mealy mouthed terms are used, people misunderstand and fail to take effective action. The results are wasted time, misused staff, lost revenue and increased costs. If business is to be productive, it must adhere to the basic principles of English grammar and vocabulary. ERI students undergo a rigorous course of instruction that develops and expands their abilities to properly use the English language in all facets of business.

The course has four phases: identify misused and corrupted use of nouns, verbs, and adjectives; provide the tools on when and how to use correct terminology; educate in the correct and appropriate application of grammar; demonstrate how best to use and present terminology for positive results. Courses vary from four to six weeks, depending upon the intensity of course material required for the students.

Credentials

As Chief Information Officer, Bennett directed all systems development, operations and network support for a leading mutual fund processing firm, based in New York City.

He directed information technology, operations, marketing and human resources for a large regional commercial bank and trust company, based in the mid west.

As a managing director for a consulting firm in Chicago, he directed several operations audits, systems conversions, and corporate planning projects for banks, thrifts and insurance companies, both overseas and in the States.

Bennett started his business career with a large California-based commercial bank in its controller’s department, managing financial systems and analysis.

Bennett Quillen has addressed a variety of industry groups e.g. Bank Administration Institute, Treasury Management Association, NACHA conferences, Credit and Lending Association and Washington University in St Louis. He has served on the Board of Directors of MAPEX, an item and electronic clearinghouse, in the mid west.

Bennett Quillen holds a BS degree in chemistry and mathematics from The Principia College and a MBA in industrial management and finance from the University of Southern California.

Contact Information

Telephone: 704.907.5235
Email: bquillen@qandans.net

Quillen’s English Rehabilitation Institute

Bennett Quillen is the founder and president of the English Rehabilitation Institute (ERI). Its purpose is to stem and reverse the current negative trend in the misuse and abuse of the English language in business. Today’s business is fraught with the contagion of abusive English practices e.g. twisting verbs into nouns and producing meaningless, even potentially damaging, words. ERI rehabilitates its students to become confident, productive users of the English language, thus benefiting themselves, their associates and their employers.

Bennett possesses over 35 years of broad experience in delivering speeches, conducting seminars and writing proposals and reports for companies, colleges and universities, and not-for-profit institutions. . He held a variety of senior executive and program management roles in operations and information technology. His consulting activities include companies throughout North America, Europe and the Middle East.

One of the keys to his success is the correct application and usage of the English language. His knowledge of the correct application of grammar and vocabulary has earned him the distinctive title of “Grammar Guru”. His success in business is directly dependent upon adopting correct terminology for the task at hand and avoiding sloppy, meaningless clichés.

To this end, Bennett Quillen founded the English Rehabilitation Institute (ERI), LLC. Today’s business is beset by the constant misuse, or downright corruption, of words. When meaningless or mealy mouthed terms are used, people misunderstand and fail to take effective action. The results are wasted time, misused staff, lost revenue and increased costs. If business is to be productive, it must adhere to the basic principles of English grammar and vocabulary. ERI students undergo a rigorous course of instruction that develops and expands their abilities to properly use the English language in all facets of business.

The course has four phases: identify misused and corrupted use of nouns, verbs, and adjectives; provide the tools on when and how to use correct terminology; educate in the correct and appropriate application of grammar; demonstrate how best to use and present terminology for positive results. Courses vary from four to six weeks, depending upon the intensity of course material required for the students.

Credentials

As Chief Information Officer, Bennett directed all systems development, operations and network support for a leading mutual fund processing firm, based in New York City.

He directed information technology, operations, marketing and human resources for a large regional commercial bank and trust company, based in the mid west.

As a managing director for a consulting firm in Chicago, he directed several operations audits, systems conversions, and corporate planning projects for banks, thrifts and insurance companies, both overseas and in the States.

Bennett started his business career with a large California-based commercial bank in its controller’s department, managing financial systems and analysis.

Bennett Quillen has addressed a variety of industry groups e.g. Bank Administration Institute, Treasury Management Association, NACHA conferences, Credit and Lending Association and Washington University in St Louis. He has served on the Board of Directors of MAPEX, an item and electronic clearinghouse, in the mid west.

Bennett Quillen holds a BS degree in chemistry and mathematics from The Principia College and a MBA in industrial management and finance from the University of Southern California.

Contact Information

Telephone: 704.907.5235
Email: bquillen@qandans.net

English Rehabilitation – Bennett B Quillen

Bennett Quillen is the founder and president of the English Rehabilitation Institute (ERI). Its purpose is to stem and reverse the current negative trend in the misuse and abuse of the English language in business. Today’s business is fraught with the contagion of abusive English practices e.g. twisting verbs into nouns and producing meaningless, even potentially damaging, words. ERI rehabilitates its students to become confident, productive users of the English language, thus benefiting themselves, their associates and their employers.

Bennett possesses over 35 years of broad experience in delivering speeches, conducting seminars and writing proposals and reports for companies, colleges and universities, and not-for-profit institutions. . He held a variety of senior executive and program management roles in operations and information technology. His consulting activities include companies throughout North America, Europe and the Middle East.

One of the keys to his success is the correct application and usage of the English language. His knowledge of the correct application of grammar and vocabulary has earned him the distinctive title of “Grammar Guru”. His success in business is directly dependent upon adopting correct terminology for the task at hand and avoiding sloppy, meaningless clichés.

To this end, Bennett Quillen founded the English Rehabilitation Institute (ERI), LLC. Today’s business is beset by the constant misuse, or downright corruption, of words. When meaningless or mealy mouthed terms are used, people misunderstand and fail to take effective action. The results are wasted time, misused staff, lost revenue and increased costs. If business is to be productive, it must adhere to the basic principles of English grammar and vocabulary. ERI students undergo a rigorous course of instruction that develops and expands their abilities to properly use the English language in all facets of business.

The course has four phases: identify misused and corrupted use of nouns, verbs, and adjectives; provide the tools on when and how to use correct terminology; educate in the correct and appropriate application of grammar; demonstrate how best to use and present terminology for positive results. Courses vary from four to six weeks, depending upon the intensity of course material required for the students.

Credentials

As Chief Information Officer, Bennett directed all systems development, operations and network support for a leading mutual fund processing firm, based in New York City.

He directed information technology, operations, marketing and human resources for a large regional commercial bank and trust company, based in the mid west.

As a managing director for a consulting firm in Chicago, he directed several operations audits, systems conversions, and corporate planning projects for banks, thrifts and insurance companies, both overseas and in the States.

Bennett started his business career with a large California-based commercial bank in its controller’s department, managing financial systems and analysis.

Bennett Quillen has addressed a variety of industry groups e.g. Bank Administration Institute, Treasury Management Association, NACHA conferences, Credit and Lending Association and Washington University in St Louis. He has served on the Board of Directors of MAPEX, an item and electronic clearinghouse, in the mid west.

Bennett Quillen holds a BS degree in chemistry and mathematics from The Principia College and a MBA in industrial management and finance from the University of Southern California.

Contact Information

Telephone: 704.907.5235
Email: bquillen@qandans.net