Managing Treasury Management service risk is as important as managing credits. There are several TM services that carry credit risk similar as if they were loan facilities to business customers, as well as other risks. Therefore, it is necessary to conduct service risk assessments and also ensure the businesses using these services are credit worthy.
So where do you begin? How do you identify those services and ensure they are used in a safe and sound manner? You ask similar questions as when you lend money to a business customer: Will the institution get paid back once the money is gone? Does this business have the capacity to support the debt in case the transaction is done and there are no funds to back it up? Let’s examine these services closer:
This product is probably the highest risk-rated service at your institution. If your employees don’t follow the appropriate policies, processes, and procedures, once you click “submit,” the money is gone. Therefore, it is imperative that your procedures are followed exactly as written to ensure the institution is not liable if the wire is fraudulent. Additionally, the platform used to initiate and approve wire transfers must have multifactor authentication capabilities and authority levels—both at the customer’s site as well as internally for employees to approve based on their own limits. There is Operational, Technology, Compliance/Regulatory, and Credit Risk when extending wire transfer capabilities to business customers.
Automated Clearing House (ACH)
Direct Deposit of Payroll is probably the most common service institutions offer to business customers. However, businesses are increasingly utilizing ACH to pay their bills because of the additional cash flow control and because it’s significantly cheaper than checks or wires. Businesses select the specific date for the batch of payments to clear their account. From the risk perspective, once the batch leaves, the institution can only retrieve the funds within a specified timeframe and following specific ACH rules. If the business account does not have collected funds, the institution is out the money. Therefore, ACH services are similar to an open Line of Credit and thus bankers must approve this TM service as a credit facility. As with wires, there is Operational, Technology, Compliance/Regulatory, and Credit Risk for ACH services offered to businesses.
Remote Deposit Capture (RDC)
The RDC carries the same risks as the other two services, but it works differently. The primary risk with RDC comes from customers potentially depositing the same physical check more than once, and in more than one institution.
Current scanners have technology to identify payee, routing number, account number, check number, amounts, and even the handwritten amounts. However, there is still a possibility of a fraudulent check deposited at different financial institutions within a certain period of time where it is undetected (at least for a few hours before posting to the accounts). Therefore, institutions must implement policies establishing daily and aggregate limits for checks deposited via RDC. The systems can automatically approve any amount, but the institution must approve each business customer up to a certain limit and treat each deposit as an extension of credit.
Unfortunately, many institutions review all checks deposited via RDC for all customers manually after a certain amount determined by the institution’s policy making this service costly and inefficient. In addition, most institutions grant immediate access to the funds deposited via RDC. For these two main reasons, businesses that utilize this product must obtain credit approval before they use it. Most institutions provide the credit approval at the time of making a loan to the business customer. For depository-only clients, the institution provides credit approval even if the customer does not have a loan.
Consumers and very small businesses use the Mobile Deposit service with few exceptions. Mobile Deposit carries the same risks as RDC. The key determining factor as to which service a business should use, RDC or Mobile Deposit, is volume. Only businesses should use the RDC service. All consumers can use Mobile Deposit. However, the daily limits for consumers is typically lower than for businesses.
Managing treasury management service risk is as important as managing credits and is part of the overall enterprise risk management program of your institution. The purpose of this blog is to explain the various risk categories that each of these important treasury management products brings to the institution. Conduct service risk assessments on these services and ensure your institution is mitigating all the risks. In the end, all other risk categories affect your reputational risk.
Businesses expect community banks and now credit unions to offer these services. Otherwise, you are not competitive. Institutions price loans based on risk. The question I leave you with is this: Do you charge for these services especially now that you understand the additional risks your institution takes by offering them?
As always, we are here to help.
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