TO: Chief Executive Officers of all National Banks, Department and Division Heads, and all Examining Personnel

Size: px
Start display at page:

Download "TO: Chief Executive Officers of all National Banks, Department and Division Heads, and all Examining Personnel"

Transcription

1 AL 96-7 Subject: Credit Card Preapprved Slicitatins TO: Chief Executive Officers f all Natinal Banks, Department and Divisin Heads, and all Examining Persnnel PURPOSE The purpse f this advisry letter is t alert natinal banks t risks assciated with preapprved slicitatins f credit cards. While sme f the infrmatin presented can als apply t credit cards issued thrugh ther means such as a cmpleted applicatin, this Advisry Letter is fcused n preapprved slicitatin prgrams where a credit card issuer uses a list f ptential custmers frm which it will make a firm ffer f credit. The Advisry Letter discusses hw prper risk assessment, cntrls, and planning can achieve the desired prtfli quality even in a perid f adverse ecnmic trends. BACKGROUND An increase in cmpetitin in the credit card business, rapid prtfli grwth rates, and the availability f diverse credit card prducts have all changed the nature f credit card lending in recent years. Althugh accunting fr nly a relatively small percentage f ttal cmmercial bank assets, credit card lans have grwn faster than any ther type f cnsumer lans ver the past 3 years. Recently there have been prnunced increases in the rates f default and delinquency fr credit card lans. Aggressive cmpetitin recently has pressured sme banks t frg custmary and effective testing f new credit card prducts and preapprved slicitatin campaigns in hpes f capturing a prduct market befre a cmpetitr. Despite the relatively small average lan size and high net interest margins in credit card lending, the default and delinquency trends are areas f cncern fr bth bankers and regulatrs. Althugh this advisry discusses risks assciated with preapprved slicitatins fr credit cards, the OCC cautins that similar risks may arise as banks use preapprved slicitatins fr ther types f cnsumer lending such as hme equity lines, small business and installment lans. The OCC has identified certain weaknesses in sme preapprved slicitatin prgrams which can impair management's ability t prmptly recgnize and respnd t existing and ptential risks in their prtflis. These weaknesses are: Lack f a cmprehensive and independent risk management functin. Failure t adequately test and analyze ptential markets fr credit card slicitatins. Adverse selectin f slicited custmers resulting in a higher than expected verall risk prfile f bked accunts.

2 Changes in underwriting criteria t increase card riginatins withut prper testing and fllw up r withut analysis f prir experience. Failure t adequately mnitr the actual perfrmance f new prducts cmpared with initial prjectins. MANAGING RISKS IN CREDIT CARD LENDING Identifying and Mnitring Risk The risk management functin, which may be lcated within the credit card area, prmtes early and accurate identificatin f existing and ptential prblems, identifies the need fr plicy revisins, and prvides management with the infrmatin it needs t respnd prmptly t changes. At a minimum, the risk management functin shuld include respnsibility fr: Perfrming prduct analyses t serve as the basis fr underwriting, marketing, and prtfli management decisins. Ensuring that marketing initiatives reflect levels f risk acceptable t management. Managing and maintaining decisin making systems which may include scring systems. Mnitring the perfrmance f the prtfli, including the perfrmance f specific prducts, marketing initiatives, analysis by riginatin (vintages) r ther cmmn factr, and ther perfrmance measures. Analyzing delinquencies and lsses in the prtfli and identifying causes f changes r trends. Ensuring cmpliance with cnsumer prtectin laws and regulatins. Reprting apprpriate risk management infrmatin t senir management and the bard f directrs. Testing New Markets Marketing is critical t the success r failure f a credit card peratin. As apprpriate, management shuld require that marketing staff: Dcument each marketing initiative as apprpriate. Track and analyze successes and failures f previus prduct initiatives t help refine current and future ffers. Use sufficient mdeling technlgy t segment and target apprpriate markets. Invlve all applicable areas in the prduct planning prcess

3 t avid subsequent prblems due t inadequate systems and staffing. Allw fr adequate time t test market a prduct and mnitr its credit quality befre the prduct is fully implemented. Reprt apprpriate market testing infrmatin t senir management and the bard f directrs. Targeting Creditwrthy Custmers When a bank decides t ffer a prduct t an identified market, it has in mind individuals that fit a certain custmer prfile. Adverse selectin ccurs when thse respnding t a prduct ffering have, n average, different credit prspects than the targeted ppulatin. This may ccur because the bank des nt fully understand the market r is using nncurrent infrmatin in its analysis. Adverse selectin may result in a prduct that is ffered at a price that des nt cver the ptential risk fr a given market as well as in greater-than-anticipated lsses in respnse t a slicitatin. Management can minimize adverse selectin by: Reviewing prduct and underwriting guidelines t ensure cnsistency with the bank's lng-term bjectives and desired custmer prfile. Setting pricing at levels that cmpensate fr risk while remaining cmpetitive in the market. Cnducting nging testing f risk-based price assumptins t determine if adverse selectin has been cntrlled fr future prduct fferings. Using the prescreened list f brrwers prmptly after receipt frm the credit bureau t help ensure that credit is extended nly t individuals meeting the specified standards. Using a deadline fr ffer acceptance. Prperly Testing Slicitatin Offers A bank shuld gather apprpriate data and devte sufficient resurces t analyze the effect f changes in underwriting criteria n its credit card prtfli. Befre lwering cutff scres t increase credit card riginatins, a bank shuld test a sample f lans and analyze any prir experience, as apprpriate, t determine whether the level f risk can be managed, apprpriately priced, and is cnsistent with the bank's verall strategic bjectives. The testing shuld: Take place ver an apprpriate perid f time befre changes t underwriting standards are fully implemented. Use apprpriate systems and analytical tls t analyze

4 results. Use perfrmance data frm recently acquired accunts fr mdeling and frecasting purpses. Mnitr warning signs f market deteriratin, such as increases in persnal bankruptcies, which may affect the accuracy f mdel assumptins. Use analysts with experience in interpreting the mdels and frecasts selected. Mnitring the Perfrmance f Accunts Bked thrugh Slicitatins Banks shuld perfrm regular analyses f new slicitatins and prducts t cmpare actual perfrmance with initial assumptins. Peridic reprts and analyses n the perfrmance f individual mailings shuld include the fllwing infrmatin: Data t measure prtfli quality f slicited accunts such as trends in delinquencies, bankruptcies, lsses, behavir scre distributins, and usage f the accunt. Infrmatin n new business by initiative, surce, and prduct. Detail n credit quality indicatrs such as credit scre distributin. Prtfli statistics that can be tracked against cmparable industry statistics. RISKS IN CREDIT CARD LENDING The preapprved slicitatin activities discussed in this advisry letter expse a bank t credit, transactin, liquidity, strategic, reputatin, and cmpliance risk. These risks are summarized belw. A mre detailed discussin f these risks and their management fr credit card prtflis can be fund in The Credit Card Lending sectin f the Cmptrller's Handbk. Credit Risk The risk t earnings r capital f an bligr's failure t meet the terms f any cntract with the bank r therwise fail t perfrm as agreed. Aggressive slicitatin prgrams may increase the bank's credit risk if the resulting credit card accunts experience higher than prjected delinquencies and lsses. Transactin Risk The risk t earnings r capital arising frm prblems with service r prduct delivery. An influx f new accunts frm a slicitatin may increase risk if a bank is unable t prcess the respnses in an accurate r timely manner. Liquidity Risk The risk t earnings r capital arising frm a bank's inability t meet its bligatins when they cme due

5 withut incurring unacceptable lsses, including the inability t manage unplanned decreases r changes in funding surces. Higher risk assets, resulting frm weaknesses in slicitatin prgrams, may be difficult t securitize r sell and thus impact a bank's liquidity. Higher than anticipated delinquencies r lsses in securitized pls may lead t market pressure n the bank t prvide additinal supprt t the pl. OCC Bulletin prvides additinal infrmatin n the risks assciated with securitizatin prgrams. Strategic Risk The risk t earnings r capital arising frm adverse business decisins r imprper implementatin f thse decisins. Failure t adequately test a new market, analyze test results, and refine subsequent slicitatin ffers may result in unsuccessful marketing effrts r accunts that d nt perfrm as anticipated. Reputatin Risk The risk t earnings r capital arising frm negative public pinin. Prly underwritten r perfrming receivables can affect a bank's reputatin as a credit card issuer and as an underwriter f credit card securitizatins. This creates a risk that future credit enhancements fr securitizing credit card receivables may be mre cstly, reduced, r may nt be available. If a bank's reputatin as an underwriter is impaired, future accessibility t financial markets may be limited r cst mre. Cmpliance Risk The risk t earnings r capital arising frm negative public pinin. Preapprved slicitatins must cmply with the FFIEC Interagency Plicy Statement n Prescreening by Financial Institutins and the Fair Credit Reprting Act (see OCC BB 91-50). The Fair Credit Reprting Act is a cnsumer prtectin law which carries civil liability fr negligent and willful nncmpliance. RISK MANAGEMENT OPTIONS Inadequate management f risks in credit card lending can lead t prtfli deteriratin and may have negative balance sheet and earnings implicatins. Apprpriate respnses t prtfli deteriratin may include: Limiting slicitatins. Tightening credit standards. Increasing the quality f analysis f ptentially creditwrthy brrwers by prviding the credit bureau with cmprehensive credit criteria t prescreen applicants. Increasing the experience f staff assigned t cnduct such analyses. Onging mnitring f the payment perfrmance f high-risk custmers in existing accunts.

6 Tracking accunts experiencing adverse trends. Strengthening cllectin effrts. A bank with a deterirating credit card prtfli may need t reassess its allwance fr lan and lease lss (ALLL) allcatins and its capital psitin. Greater inherent lss in the credit card prtfli may require additinal ALLL allcatins under GAAP. Increased verall risk caused by declining credit quality r weakening risk management practices may require the supprt f additinal capital. CONCLUSION The OCC encurages each natinal bank invlved in credit card lending t evaluate its business plan, current peratins, and risk management cntrl systems. Management shuld take apprpriate actin t limit its expsure t unwarranted risks. ORIGINATING OFFICE Questins cncerning this advisry letter shuld be addressed t the Office f Chief Natinal Bank Examiner at (202) Jimmy F. Bartn Chief Natinal Bank Examiner Date: September 26, 1996

The Total Economic Impact of cleverbridge Executive Summary

The Total Economic Impact of cleverbridge Executive Summary A Frrester Ttal Ecnmic Impact Study Prepared Fr cleverbridge Executive Summary (Fr the full case study, please g t: http://www.cleverbridge.cm/crprate/tei-pages/tei-landingpage) Prject Directr: Reggie

More information

Disclosures about the Credit Quality of Financing Receivables and the Allowance for Credit Losses

Disclosures about the Credit Quality of Financing Receivables and the Allowance for Credit Losses Disclsures abut the Credit Quality f Financing Receivables and the Allwance fr Credit Lsses During July 2010 the FASB issued Accunting Standards Update 2010-20 Disclsures abut the Credit Quality f Financing

More information

UNIVERSITY OF CALIFORNIA MERCED PERFORMANCE MANAGEMENT GUIDELINES

UNIVERSITY OF CALIFORNIA MERCED PERFORMANCE MANAGEMENT GUIDELINES UNIVERSITY OF CALIFORNIA MERCED PERFORMANCE MANAGEMENT GUIDELINES REFERENCES AND RELATED POLICIES A. UC PPSM 2 -Definitin f Terms B. UC PPSM 12 -Nndiscriminatin in Emplyment C. UC PPSM 14 -Affirmative

More information

What to Expect from a CFPB Audit The following is an article written by one of AllRegs experts that have just come through a CFPB audit.

What to Expect from a CFPB Audit The following is an article written by one of AllRegs experts that have just come through a CFPB audit. Sales & Supprt: (800) 848-4904 Fax: (651) 686-0906 2600 Eagan Wds Drive, Suite 220, Eagan, MN 55121 What t Expect frm a CFPB Audit The fllwing is an article written by ne f AllRegs experts that have just

More information

RISK MANAGEMENT POLICY

RISK MANAGEMENT POLICY PREAMBLE RISK MANAGEMENT POLICY Risk is inherent in all administrative and business activities. Risks are such events r the cnditins that has a harmful r negative impact n the rganizatinal gal r its business

More information

CASSOWARY COAST REGIONAL COUNCIL POLICY ENTERPRISE RISK MANAGEMENT

CASSOWARY COAST REGIONAL COUNCIL POLICY ENTERPRISE RISK MANAGEMENT CASSOWARY COAST REGIONAL COUNCIL POLICY ENTERPRISE RISK MANAGEMENT Plicy Number: 2.20 1. Authrity Lcal Gvernment Act 2009 Lcal Gvernment Regulatin 2012 AS/NZS ISO 31000-2009 Risk Management Principles

More information

Internal Audit Charter and operating standards

Internal Audit Charter and operating standards Internal Audit Charter and perating standards 2 1 verview This dcument sets ut the basis fr internal audit: (i) the Internal Audit charter, which establishes the framewrk fr Internal Audit; and (ii) hw

More information

CRSP Index Governance Committees Terms of Reference. Introduction... 2 Governance and Oversight Control Framework... 3 Index Oversight Committee...

CRSP Index Governance Committees Terms of Reference. Introduction... 2 Governance and Oversight Control Framework... 3 Index Oversight Committee... CRSP Index Gvernance Cmmittees Terms f Reference CRSP Center fr Research in Security Prices The University f Chicag Bth Schl f Business Chicag, IL 60603 Intrductin... 2 Gvernance and Oversight Cntrl Framewrk...

More information

Audit Committee Charter

Audit Committee Charter Audit Cmmittee Charter Membership The Audit Cmmittee (the "Cmmittee") f the Bard f Directrs (the "Bard") f Philip Mrris Internatinal Inc. (the "Cmpany") shall cnsist f at least three directrs all f whm

More information

MSB FINANCIAL CORP. MILLINGTON BANK AUDIT COMMITTEE CHARTER

MSB FINANCIAL CORP. MILLINGTON BANK AUDIT COMMITTEE CHARTER MSB FINANCIAL CORP. MILLINGTON BANK AUDIT COMMITTEE CHARTER This Audit Cmmittee Charter has been amended as f July 17, 2015. The Audit Cmmittee shall review and reassess this Charter annually and recmmend

More information

THE CITY UNIVERSITY OF NEW YORK IDENTITY THEFT PREVENTION PROGRAM

THE CITY UNIVERSITY OF NEW YORK IDENTITY THEFT PREVENTION PROGRAM THE CITY UNIVERSITY OF NEW YORK IDENTITY THEFT PREVENTION PROGRAM 1. Prgram Adptin The City University f New Yrk (the "University") develped this Identity Theft Preventin Prgram (the "Prgram") pursuant

More information

Chapter 7 Business Continuity and Risk Management

Chapter 7 Business Continuity and Risk Management Chapter 7 Business Cntinuity and Risk Management Sectin 01 Business Cntinuity Management 070101 Initiating the Business Cntinuity Plan (BCP) Purpse: T establish the apprpriate level f business cntinuity

More information

Business Plan Overview

Business Plan Overview Business Plan Overview Organizatin and Cntent Summary A business plan is a descriptin f yur business, including yur prduct yur market, yur peple and yur financing needs. Yu shuld cnsider that a well prepared

More information

SOL PLAATJE MUNICIPALITY POLICY ON INTERNAL AUDIT

SOL PLAATJE MUNICIPALITY POLICY ON INTERNAL AUDIT SOL PLAATJE MUNICIPALITY POLICY ON INTERNAL AUDIT Apprved As Per Reslutin CR 500 dd 17-11-2005 Sl Plaatje Municipality POLICY REGARDING THE ROLE AND RESPONSIBILITY OF THE INTERNAL AUDIT DEPARTMENT (THE

More information

NYU Langone Medical Center NYU Hospitals Center NYU School of Medicine

NYU Langone Medical Center NYU Hospitals Center NYU School of Medicine Title: Identity Theft Prgram Effective Date: July 2009 NYU Langne Medical Center NYU Hspitals Center NYU Schl f Medicine POLICY It is the plicy f the NYU Langne Medical Center t educate and train staff

More information

CMS Eligibility Requirements Checklist for MSSP ACO Participation

CMS Eligibility Requirements Checklist for MSSP ACO Participation ATTACHMENT 1 CMS Eligibility Requirements Checklist fr MSSP ACO Participatin 1. General Eligibility Requirements ACO participants wrk tgether t manage and crdinate care fr Medicare fee-fr-service beneficiaries.

More information

Federal Trade Commission s Red Flags rule

Federal Trade Commission s Red Flags rule Federal Trade Cmmissin s Red Flags rule As part f the Federal Trade Cmmissin s (FTC's) implementatin f the Fair and Accurate Credit Transactins (FACT) Act f 2003, medical prviders may need t cmply with

More information

FINANCIAL SERVICES FLASH REPORT

FINANCIAL SERVICES FLASH REPORT FINANCIAL SERVICES FLASH REPORT Draft Regulatry Cmpliance Management Guideline Released by the Office f the Superintendent f Financial Institutins May 5, 2014 On April 30, 2014, the Office f the Superintendent

More information

- Upfront fee of $ + GST - Ongoing fee commencing immediately after plan implementation of $20.00 + GST per fortnight.

- Upfront fee of $ + GST - Ongoing fee commencing immediately after plan implementation of $20.00 + GST per fortnight. Cntract f engagement This cntract f engagement is between FSB 4 Financial Limited (the adviser) and (the client). Purpse This cntract establishes the relatinship between the adviser and the client relating

More information

BENEFITFOCUS, INC. CORPORATE COMMUNICATIONS POLICY

BENEFITFOCUS, INC. CORPORATE COMMUNICATIONS POLICY BENEFITFOCUS, INC. CORPORATE COMMUNICATIONS POLICY I. PURPOSE T establish guidelines fr the disclsure f infrmatin regarding Benefitfcus, Inc. ( Benefitfcus ) t the investing public, market analysts, brkers,

More information

POLICY 1390 Information Technology Continuity of Business Planning Issued: June 4, 2009 Revised: June 12, 2014

POLICY 1390 Information Technology Continuity of Business Planning Issued: June 4, 2009 Revised: June 12, 2014 State f Michigan POLICY 1390 Infrmatin Technlgy Cntinuity f Business Planning Issued: June 4, 2009 Revised: June 12, 2014 SUBJECT: APPLICATION: PURPOSE: CONTACT AGENCY: Plicy fr Infrmatin Technlgy (IT)

More information

Better Practice Guide Financial Considerations for Government use of Cloud Computing

Better Practice Guide Financial Considerations for Government use of Cloud Computing Better Practice Guide Financial Cnsideratins fr Gvernment use f Clud Cmputing Nvember 2011 Intrductin Many Australian Gvernment agencies are in the prcess f cnsidering the adptin f clud-based slutins.

More information

MANITOBA SECURITIES COMMISSION STRATEGIC PLAN 2013-2016

MANITOBA SECURITIES COMMISSION STRATEGIC PLAN 2013-2016 MANITOBA SECURITIES COMMISSION STRATEGIC PLAN 2013-2016 The Manitba Securities Cmmissin (the Cmmissin) is a divisin f the Manitba Financial Services Agency (MFSA). The ther divisin is the Financial Institutins

More information

THIRD PARTY PROCUREMENT PROCEDURES

THIRD PARTY PROCUREMENT PROCEDURES ADDENDUM #1 THIRD PARTY PROCUREMENT PROCEDURES NORTH CENTRAL TEXAS COUNCIL OF GOVERNMENTS TRANSPORTATION DEPARTMENT JUNE 2011 OVERVIEW These prcedures establish standards and guidelines fr the Nrth Central

More information

RI Student Loan Authority

RI Student Loan Authority RI Student Lan Authrity Executive Summary f Strategic Plan Apprved by RISLA Bard f Directrs Octber 17, 2014 Missin Statement: Cnsistent with the authrity granted by the General Assembly f the State f Rhde

More information

WHAT YOU NEED TO KNOW ABOUT. Protecting your Privacy

WHAT YOU NEED TO KNOW ABOUT. Protecting your Privacy WHAT YOU NEED TO KNOW ABOUT Prtecting yur Privacy YOUR PRIVACY IS OUR PRIORITY Credit unins have a histry f respecting the privacy f ur members and custmers. Yur Bard f Directrs has adpted the Credit Unin

More information

Investment Policy Statement

Investment Policy Statement Investment Plicy Statement The fllwing dcument is in tw sectins. Please click the bkmark at left that refers t yur specific retirement plan. SECTION 1: Trustee 401(k) Plan (Capital Accumulatin Plan) SECTION

More information

Credit Work Group Recommendation

Credit Work Group Recommendation Credit Wrk Grup Recmmendatin T: Credit Wrk Grup Frm: Mike Bixby (305) 829-5549 mbixby@inf1team.cm Paul Wills (770) 740-7353 Paul.Wills@equifax.cm Date: Octber 7, 2004 Re: FACT Act Implicatins and Recmmendatins

More information

VCU Payment Card Policy

VCU Payment Card Policy VCU Payment Card Plicy Plicy Type: Administrative Respnsible Office: Treasury Services Initial Plicy Apprved: 12/05/2013 Current Revisin Apprved: 12/05/2013 Plicy Statement and Purpse The purpse f this

More information

COPIES-F.Y.I., INC. Policies and Procedures Data Security Policy

COPIES-F.Y.I., INC. Policies and Procedures Data Security Policy COPIES-F.Y.I., INC. Plicies and Prcedures Data Security Plicy Page 2 f 7 Preamble Mst f Cpies FYI, Incrprated financial, administrative, research, and clinical systems are accessible thrugh the campus

More information

Corporate Standards for data quality and the collation of data for external presentation

Corporate Standards for data quality and the collation of data for external presentation The University f Kent Crprate Standards fr data quality and the cllatin f data fr external presentatin This paper intrduces a set f standards with the aim f safeguarding the University s psitin in published

More information

Sources of Federal Government and Employee Information

Sources of Federal Government and Employee Information Inf Surce Surces f Federal Gvernment and Emplyee Infrmatin Ridley Terminals Inc. TABLE OF CONTENTS General Infrmatin Intrductin t Inf Surce Backgrund Respnsibilities Institutinal Functins, Prgram and Activities

More information

Audit Committee Charter. St Andrew s Insurance (Australia) Pty Ltd St Andrew s Life Insurance Pty Ltd St Andrew s Australia Services Pty Ltd

Audit Committee Charter. St Andrew s Insurance (Australia) Pty Ltd St Andrew s Life Insurance Pty Ltd St Andrew s Australia Services Pty Ltd Audit Cmmittee Charter St Andrew s Insurance (Australia) Pty Ltd St Andrew s Life Insurance Pty Ltd St Andrew s Australia Services Pty Ltd Versin 2.0, 22 February 2016 Apprver Bard f Directrs St Andrew

More information

Change Management Process

Change Management Process Change Management Prcess B1.10 Change Management Prcess 1. Intrductin This plicy utlines [Yur Cmpany] s apprach t managing change within the rganisatin. All changes in strategy, activities and prcesses

More information

Outsourcing arrangements

Outsourcing arrangements Rules Ntice Guidance Nte Dealer Member Rules Please distribute internally t: Internal Audit Legal and Cmpliance Operatins Regulatry Accunting Senir Management Cntacts: Luis Piergeti Vice President, Financial

More information

HOW TO SELECT A LIFE INSURANCE COMPANY

HOW TO SELECT A LIFE INSURANCE COMPANY HOW TO SELECT A LIFE INSURANCE COMPANY There will prbably be hundreds f life insurance cmpanies t chse frm when yu decide t purchase a life insurance plicy. Hw d yu decide which ne? Mst cmpanies are quite

More information

GREEN MOUNTAIN ENERGY COMPANY

GREEN MOUNTAIN ENERGY COMPANY GREEN MOUNTAIN ENERGY COMPANY INDEPENDENT ACCOUNTANT S REPORT ON APPLYING AGREED-UPON PROCEDURES DECEMBER 31, 2012 INDEPENDENT ACCOUNTANT S REPORT ON APPLYING AGREED-UPON PROCEDURES T Green Muntain Energy

More information

CDC UNIFIED PROCESS PRACTICES GUIDE

CDC UNIFIED PROCESS PRACTICES GUIDE Dcument Purpse The purpse f this dcument is t prvide guidance n the practice f Business Case and t describe the practice verview, requirements, best practices, activities, and key terms related t these

More information

ENTERPRISE RISK MANAGEMENT ENTERPRISE RISK MANAGEMENT POLICY

ENTERPRISE RISK MANAGEMENT ENTERPRISE RISK MANAGEMENT POLICY ENTERPRISE RISK MANAGEMENT POLICY Plicy N. 10014 Review Date Octber 1, 2014 Effective Date March 1, 2014 Crss- Respnsibility Vice President, Reference Administratin Apprver Executive Cuncil 1. 1. Plicy

More information

GCSE Business Studies

GCSE Business Studies GCSE Business Studies The students will sit tw examinatins in the summer: Examinatin: AQA Unit 1: Setting up a Business (413001) Exam Date: Wednesday 25 May 2016. 40% f the verall GCSE qualificatin Examinatin:

More information

Statistical sampling involves the use of techniques from which mathematically constructed conclusions regarding the population can be drawn.

Statistical sampling involves the use of techniques from which mathematically constructed conclusions regarding the population can be drawn. SECTION I.3B AUDIT ENGAGEMENT SAMPLING Intrductin: In frming an audit pinin auditrs frequently d nt examine all f the infrmatin available as it may be impractical and valid cnclusins can be reached using

More information

NAIC Replacement Requirements For Certain Life Insurance Policies And Annuity Contracts

NAIC Replacement Requirements For Certain Life Insurance Policies And Annuity Contracts NAIC Replacement Requirements Fr Certain Life Insurance Plicies And Annuity Cntracts Duties f Prducers If a transactin invlves a replacement, the prducer must leave with the applicant, at the time an applicatin

More information

Purchasing Policy Checklist for Procurement with Federal Grants Eileen Youens, JD

Purchasing Policy Checklist for Procurement with Federal Grants Eileen Youens, JD Purchasing Plicy Checklist fr Prcurement with Federal Grants Eileen Yuens, JD T cmply with the Unifrm Administrative Requirements, Cst Principles, and Audit Requirements fr Financial Awards (the Super

More information

Process Improvement Center of Excellence Service Proposal Recommendation. Operational Oversight Committee Report Submission

Process Improvement Center of Excellence Service Proposal Recommendation. Operational Oversight Committee Report Submission Prcess Imprvement Center f Excellence Service Prpsal Recmmendatin Operatinal Oversight Cmmittee Reprt Submissin INTRODUCTION This Prpsal prvides initial infrmatin regarding a pssible additin t a service.

More information

Research Report. Abstract: The Emerging Intersection Between Big Data and Security Analytics. November 2012

Research Report. Abstract: The Emerging Intersection Between Big Data and Security Analytics. November 2012 Research Reprt Abstract: The Emerging Intersectin Between Big Data and Security Analytics By Jn Oltsik, Senir Principal Analyst With Jennifer Gahm Nvember 2012 2012 by The Enterprise Strategy Grup, Inc.

More information

Risk Management Policy AGL Energy Limited

Risk Management Policy AGL Energy Limited Risk Management Plicy AGL Energy Limited AUGUST 2014 Table f Cntents 1. Abut this Dcument... 2 2. Plicy Statement... 2 3. Purpse... 2 4. AGL Risk Cntext... 3 5. Scpe... 3 6. Objectives... 3 7. Accuntabilities...

More information

Key Steps for Organizations in Responding to Privacy Breaches

Key Steps for Organizations in Responding to Privacy Breaches Key Steps fr Organizatins in Respnding t Privacy Breaches Purpse The purpse f this dcument is t prvide guidance t private sectr rganizatins, bth small and large, when a privacy breach ccurs. Organizatins

More information

SecurityNational Mortgage Company Vendor Management Program

SecurityNational Mortgage Company Vendor Management Program SecurityNatinal Mrtgage Cmpany Vendr Management Prgram CONTENTS OVERVIEW... 1 VENDOR RISKS... 3 Strategic Risk... 3 Reputatin Risk... 3 Operatinal Risk... 3 Transactin Risk... 4 Credit Risk... 4 Cmpliance

More information

MEDIUM TERM AND ANNUAL AUDIT PLANNING PROCESS

MEDIUM TERM AND ANNUAL AUDIT PLANNING PROCESS Audit Manual Sectin G.1 SECTION G.1 CENTER INTERNAL AUDIT WORK PLANNING Overview f this sectin: MEDIUM TERM AND ANNUAL AUDIT PLANNING PROCESS MGT/BOT REQUESTS PREVIOUS AUDIT COVERAGE CENTER RISK ASSESSMEN

More information

INTERNATIONAL STANDARD ON AUDITING 265 COMMUNICATING DEFICIENCIES IN INTERNAL CONTROL TO THOSE CHARGED WITH GOVERNANCE AND MANAGEMENT CONTENTS

INTERNATIONAL STANDARD ON AUDITING 265 COMMUNICATING DEFICIENCIES IN INTERNAL CONTROL TO THOSE CHARGED WITH GOVERNANCE AND MANAGEMENT CONTENTS INTERNATIONAL STANDARD ON AUDITING 265 COMMUNICATING DEFICIENCIES IN INTERNAL CONTROL TO THOSE CHARGED WITH GOVERNANCE AND MANAGEMENT (Effective fr audits f financial statements fr perids beginning n r

More information

When to use a Reverse Auction or other erfx sourcing tactic

When to use a Reverse Auction or other erfx sourcing tactic When t use a Reverse Auctin r ther erfx surcing tactic Evaluating cmmdity characteristics t determine prject strategy by Iasta Overview Each erfx has a unique and primary gal. Typically, the primary gal

More information

AHI. Foreign Pre-Approval Inspections (PAIs) Points to Consider

AHI. Foreign Pre-Approval Inspections (PAIs) Points to Consider AHI Freign Pre-Apprval Inspectins (PAIs) Pints t Cnsider The fllwing suggestins are intended t prvide spnsr guidance fr timeliness and predictability f freign PAIs. The FDA Center fr Veterinary Medicine

More information

EM-22.5 Category: Topic:

EM-22.5 Category: Topic: EM-22.5 Categry: Tpic: Published: 08/20/2014 Lan Prtfli Management Lan Underwriting Overview Lan underwriting is ne f the mst critical aspects f the verall lan prtfli management (LPM) functin. Sund underwriting

More information

Appendix H. Annual Risk Assessment and Audit Plan 2013/14

Appendix H. Annual Risk Assessment and Audit Plan 2013/14 Annual Risk Assessment and Audit Plan 2013/14 Internal Audit Department September 25, 2013 Table f Cntents Intrductin.. 3 Risk Assessment Prcess... 4 Page 2 Intrductin Each year, the Internal Audit Department

More information

Systems Support - Extended

Systems Support - Extended 1 General Overview This is a Service Level Agreement ( SLA ) between and the Enterprise Windws Services t dcument: The technlgy services the Enterprise Windws Services prvides t the custmer. The targets

More information

NC Employees Workplace Program Requirements for Safety and Health. Back Protection

NC Employees Workplace Program Requirements for Safety and Health. Back Protection NC Emplyees Wrkplace Prgram Requirements fr Safety and Health Scpe Back Prtectin This sectin applies t emplyees in peratins that invlve lifting, manual material handling, manual lad lifting and basic jb

More information

ISO 9000 in Brief. Frequently Asked Questions (FAQ's)

ISO 9000 in Brief. Frequently Asked Questions (FAQ's) ISO 9000 in Brief Frequently Asked Questins (FAQ's) The ISO 9000 family f standards are amng ISO's mst widely knwn standards ever. ISO 9000 standards are implemented by all types f rganizatin in industrial

More information

Guidance on Managing Outsourcing Risk

Guidance on Managing Outsourcing Risk Guidance n Managing Outsurcing Risk Divisin f Banking Supervisin and Regulatin Divisin f Cnsumer and Cmmunity Affairs Bard f Gvernrs f the Federal Reserve System December 5, 2013 Table f Cntents I. Purpse

More information

National Australia Bank Limited Group Disclosure & External Communications Policy

National Australia Bank Limited Group Disclosure & External Communications Policy Natinal Australia Bank Limited Grup Disclsure & External Cmmunicatins Plicy Grup Disclsure & External Cmmunicatins Plicy Page 2 f 7 Grup Disclsure & External Cmmunicatins Plicy ( the Plicy ) 1. Overview

More information

6101 - DEPARTMENT OF ADMINISTRATION 14-BANKING AND FINANCIAL DIVISION

6101 - DEPARTMENT OF ADMINISTRATION 14-BANKING AND FINANCIAL DIVISION Prgram Budget Cmparisn The fllwing table summarizes the ttal executive budget fr the prgram by year, type f expenditure, and surce f funding. Prgram Budget Cmparisn Budget Item Base Fiscal 2012 Apprp.

More information

Presentation: The Demise of SAS 70 - What s Next?

Presentation: The Demise of SAS 70 - What s Next? Presentatin: The Demise f SAS 70 - What s Next? September 15, 2011 1 Presenters: Jeffrey Ziplw - Partner BlumShapir Jennifer Gerasimv Senir Manager Delitte. SAS 70 Backgrund and Overview Purpse f a SAS

More information

Trends and Considerations in Currency Recycle Devices. What is a Currency Recycle Device? November 2003

Trends and Considerations in Currency Recycle Devices. What is a Currency Recycle Device? November 2003 Trends and Cnsideratins in Currency Recycle Devices Nvember 2003 This white paper prvides basic backgrund n currency recycle devices as cmpared t the cmbined features f a currency acceptr device and a

More information

Perform Quantitative Risk Analysis

Perform Quantitative Risk Analysis Perfrm Quantitative Risk Analysis Intrductin Quantitative Risk Analysis refers t the thrugh and cmplete numeric analysis f the verall effect f the ttal quantifiable amunt f risks invlved in the prject

More information

FINANCIAL SERVICES FLASH REPORT

FINANCIAL SERVICES FLASH REPORT FINANCIAL SERVICES FLASH REPORT Interagency Guidance n Hme Equity Lines f Credit Nearing Their End-f-Draw Perids August 12, 2014 On July 1, 2014, the federal regulatry agencies fr financial institutins

More information

Financial Accountability Handbook

Financial Accountability Handbook Financial Accuntability Handbk >> Vlume 4 Mnitring/assessment Infrmatin Sheet 4.2 Statement by Chief Finance Officer Intrductin Accuntable fficers and statutry bdies are respnsible fr the efficient, effective

More information

CDC UNIFIED PROCESS PRACTICES GUIDE

CDC UNIFIED PROCESS PRACTICES GUIDE Dcument Purpse The purpse f this dcument is t prvide guidance n the practice f Risk Management and t describe the practice verview, requirements, best practices, activities, and key terms related t these

More information

2008 BA Insurance Systems Pty Ltd

2008 BA Insurance Systems Pty Ltd 2008 BA Insurance Systems Pty Ltd BAIS have been delivering insurance systems since 1993. Over the last 15 years, technlgy has mved at breakneck speed. BAIS has flurished in this here tday, gne tmrrw sftware

More information

TEB REMUNERATION POLICY

TEB REMUNERATION POLICY TEB REMUNERATION POLICY TEB Human Resurces 2013 1 / 11 Table f Cntents A/ Intrductin... 2 B/ Purpse... 3 C/ Scpe... 3 D/ Preparatin f the Remuneratin Plicy... 3 E/ Gvernance and administratin f the prcess...

More information

Select Auditing Considerations for the 2014 Audit Cycle

Select Auditing Considerations for the 2014 Audit Cycle Select Auditing Cnsideratins fr the 2014 Audit Cycle This Alert is intended t remind member firms f certain auditing cnsideratins that may be relevant fr the 2014 audit cycle. The Alert identifies and

More information

Loss Share Data Specifications Change Management Plan

Loss Share Data Specifications Change Management Plan Lss Share Data Specificatins Change Management Plan Last Updated: 2/27/2013 Table f Cntents I. Purpse... 3 II. Change Management Apprach... 3 III. Categries f Revisins... 4 IV. Help and Supprt... 6 Lss

More information

SOLUTION CORPORATE STRATEGY AND GOVERNANCE MAY 2010

SOLUTION CORPORATE STRATEGY AND GOVERNANCE MAY 2010 Pwer f Buyers The cmpany shuld cnsider the needs f its custmers in the prductin and distributin f the sap. Pwer f suppliers The management must be certain that there are available suppliers wh can prvide

More information

Phi Kappa Sigma International Fraternity Insurance Billing Methodology

Phi Kappa Sigma International Fraternity Insurance Billing Methodology Phi Kappa Sigma Internatinal Fraternity Insurance Billing Methdlgy The Phi Kappa Sigma Internatinal Fraternity Executive Bard implres each chapter t thrughly review the attached methdlgy and plan nw t

More information

EXECUTIVE DIRECTOR CORPORATE/CFO JOB & PERSON SPECIFICATION

EXECUTIVE DIRECTOR CORPORATE/CFO JOB & PERSON SPECIFICATION EXECUTIVE DIRECTOR CORPORATE/CFO JOB & PERSON SPECIFICATION MARCH 2014 POSITION TITLE : EXECUTIVE DIRECTOR CORPORATE/CFO REPORTS TO : CHIEF EXECUTIVE OFFICER Scpe f rle Reprting directly t the Chief Executive

More information

FEDERAL RESERVE BANK OF MINNEAPOLIS HIGH AND EMERGING RISK LIST June 30, 2015 (Data as of December 31, 2014) Risk List Process

FEDERAL RESERVE BANK OF MINNEAPOLIS HIGH AND EMERGING RISK LIST June 30, 2015 (Data as of December 31, 2014) Risk List Process FEDERAL RESERVE BANK OF MINNEAPOLIS HIGH AND EMERGING RISK LIST June 30, 2015 (Data as f December 31, 2014) Risk List Prcess We begin develpment f the Risk List by identifying areas f risk ptentially faced

More information

Thinking Different About Alternative Financing Options

Thinking Different About Alternative Financing Options Thinking Different Abut Alternative Financing Optins Christpher Mills Senir Business Develpment Officer Federal Natinal Cmmercial Credit This whitepaper will make yu think differently abut alternative

More information

AUDIT AND RISK COMMITTEE TERMS OF REFERENCE

AUDIT AND RISK COMMITTEE TERMS OF REFERENCE AUDIT AND RISK COMMITTEE TERMS OF REFERENCE 1. TITLE OF COMMITTEE Audit and Risk Cmmittee 2. ESTABLISHMENT The Audit and Risk Cmmittee is established under Part 3 Sectin 19(1) f the Charles Darwin University

More information

their needs. customer, and suggest alternative products when a customer requested product is not available.

their needs. customer, and suggest alternative products when a customer requested product is not available. Crescent Electrical Supply Cmpany (Denver, CO) - Crescent Electric Supply Cmpany (CESCO) was funded in 1919. Tday, it is ne f the largest electrical distributrs in the United States with ver 140 lcatins

More information

Financial Accountability Handbook

Financial Accountability Handbook Financial Accuntability Handbk >> Vlume 5 Reprting Systems Infrmatin Sheet 5.2 Preparatin f Financial Statements Intrductin The Financial Accuntability Act 2009 (the Act) and the Financial and Perfrmance

More information

Rating Criteria for Micro Small and Medium Enterprises

Rating Criteria for Micro Small and Medium Enterprises Perfrmance Capability Rating Criteria fr Micr Small and Medium Enterprises Rating Criteria fr Micr Small and Medium Enterprises ONICRA is ne f the leading Credit Rating and Perfrmance Assessment Agencies

More information

10 th May 2010. Dear Peter, Re: Audit Quality in Australia: A Strategic Review

10 th May 2010. Dear Peter, Re: Audit Quality in Australia: A Strategic Review 10 th May 2010 Mr. Peter Levy Audit Quality Strategic Review Crpratins and Financial Services Divisin The Treasury Langtn Crescent PARKES ACT 2600 Dear Peter, Re: Audit Quality in Australia: A Strategic

More information

Gravesham Borough Council

Gravesham Borough Council Classificatin: Part 1 Public Key Decisin: Please specify - N Gravesham Brugh Cuncil Reprt t: Perfrmance and Administratin Cmmittee Date: 12 Nvember 2015 Reprting fficer: Subject: Crprate Perfrmance Manager

More information

U. S. Department of Housing and Urban Development Washington, D.C. 20410-8000. December 20, 2000

U. S. Department of Housing and Urban Development Washington, D.C. 20410-8000. December 20, 2000 U. S. Department f Husing and Urban Develpment Washingtn, D.C. 20410-8000 December 20, 2000 OFFICE OF THE ASSISTANT SECRETARY FOR HOUSING-FEDERAL HOUSING COMMISSIONER MORTGAGEE LETTER 00-46 TO: ALL APPROVED

More information

SECTION 5: EVALUATION METHODOLOGY

SECTION 5: EVALUATION METHODOLOGY SECTION 5: EVALUATION METHODOLOGY The State f Oklahma will cnduct a cmprehensive, fair, and impartial evaluatin f bids received in respnse t this ITB. Technical and Cst Bids will be evaluated and scred

More information

Version Endorsed by Authorised by Approved Effective Date. 1.0 Academic Board Chief Executive Officer 11 February st Trimester 2016

Version Endorsed by Authorised by Approved Effective Date. 1.0 Academic Board Chief Executive Officer 11 February st Trimester 2016 PL_AC_010: Disability Plicy Plicy Categry Academic Dcument Owner Chief Custmer Officer Respnsible Officer Head f Academic Services Review Date December 2016 Related Dcuments Admissins Plicy Versin Endrsed

More information

HEALTH INFORMATION EXCHANGE GRANTS CRITERIA

HEALTH INFORMATION EXCHANGE GRANTS CRITERIA 1 HEALTH INFORMATION EXCHANGE GRANTS CRITERIA INTRODUCTION On August, 20 th, the federal Office f the Natinal Crdinatr fr Health Infrmatin Technlgy (ONC) released an pprtunity fr states t apply fr between

More information

DALBAR Due Diligence: Trust, but Verify

DALBAR Due Diligence: Trust, but Verify BEST INTEREST INVESTMENT RECOMMENDATIONS Advisr Rle under Best Interest Regulatins January 27, 2016 In the era when the cntractual bligatin is t act in the client s best interest, investment decisins can

More information

7/25/14 FAIRFAX COUNTY PUBLIC SCHOOLS SUPPORT EMPLOYEE PERFORMANCE ASSESSMENT HANDBOOK

7/25/14 FAIRFAX COUNTY PUBLIC SCHOOLS SUPPORT EMPLOYEE PERFORMANCE ASSESSMENT HANDBOOK 7/25/14 FAIRFAX COUNTY PUBLIC SCHOOLS SUPPORT EMPLOYEE PERFORMANCE ASSESSMENT HANDBOOK A Resurce Fr Supprt Emplyees Cpyright 2014, Fairfax Cunty Public Schls http://www.fcps.edu/hr/epd/evaluatins/supprt.shtml

More information

Version Date Comments / Changes 1.0 January 2015 Initial Policy Released

Version Date Comments / Changes 1.0 January 2015 Initial Policy Released Page 1 f 6 Vice President, Infrmatics and Transfrmatin Supprt APPROVED (S) REVISED / REVIEWED SUMMARY Versin Date Cmments / Changes 1.0 Initial Plicy Released INTENT / PURPOSE The Infrmatin and Data Gvernance

More information

Research Report. Abstract: Advanced Malware Detection and Protection Trends. September 2013

Research Report. Abstract: Advanced Malware Detection and Protection Trends. September 2013 Research Reprt Abstract: Advanced Malware Detectin and Prtectin Trends By Jn Oltsik, Senir Principal Analyst With Jennifer Gahm, Senir Prject Manager September 2013 2013 by The Enterprise Strategy Grup,

More information

U18703: Conduct an assessment of risks in the workplace

U18703: Conduct an assessment of risks in the workplace U18703: Cnduct an assessment f risks in the wrkplace Unit Descriptr: Fundamental t this unit is an understanding f the prcess f carrying ut a risk assessment. A persn cmpetent in this unit shuld be able

More information

First Global Data Corp.

First Global Data Corp. First Glbal Data Crp. Privacy Plicy As f February 23, 2015 Ding business with First Glbal Data Crp. ("First Glbal", First Glbal Mney, "we" r "us", which includes First Glbal Data Crp. s subsidiary, First

More information

FY 2014 Senior Level (SL) and Scientific or Professional (ST) Performance Appraisal System Opening Guidance

FY 2014 Senior Level (SL) and Scientific or Professional (ST) Performance Appraisal System Opening Guidance Office f Executive Resurces Office f the Chief Human Capital Officer U.S. Department f Energy FY 2014 Senir Level (SL) and Scientific r Prfessinal (ST) Perfrmance Appraisal System Opening Guidance Table

More information

.100 POLICY STATEMENT

.100 POLICY STATEMENT Treasury Management Operatins Sectin: Treasury Management Number: 105.100 Title: Treasury Management Operatins POLICY Index.100 POLICY STATEMENT.110 POLICY RATIONALE.120 AUTHORITY.130 APPROVAL AND EFFECTIVE

More information

Appendix B: Assessment Criteria

Appendix B: Assessment Criteria Appendix B: Assessment Criteria I. Standards f Gd Regulatin as Adapted fr RECA Guidance and standards Standards f cmpetence and cnduct reflect up t date practice and legislatin. They priritize public prtectin.

More information

PENETRATION TEST OF THE INDIAN HEALTH SERVICE S COMPUTER NETWORK

PENETRATION TEST OF THE INDIAN HEALTH SERVICE S COMPUTER NETWORK Department f Health and Human Services OFFICE OF INSPECTOR GENERAL PENETRATION TEST OF THE INDIAN HEALTH SERVICE S COMPUTER NETWORK Inquiries abut this reprt may be addressed t the Office f Public Affairs

More information

SECTION J QUALITY ASSURANCE AND IMPROVEMENT PROGRAM

SECTION J QUALITY ASSURANCE AND IMPROVEMENT PROGRAM Audit Manual Sectin J SECTION J QUALITY ASSURANCE AND IMPROVEMENT PROGRAM Ref. Plicy and Practice Requirements IIA Standards and Other references J 1 Plicy: The Head f Internal Audit shall develp and maintain

More information

Framework Agreement between the Department of Health and Public Health England. Annex C: Public-Facing Communications

Framework Agreement between the Department of Health and Public Health England. Annex C: Public-Facing Communications Framewrk Agreement between the Department f Health and Public Health England Annex C: Public-Facing Cmmunicatins Framewrk Agreement between the Department f Health and Public Health England: Annex C Annex

More information

How to Reduce Project Lead Times Through Improved Scheduling

How to Reduce Project Lead Times Through Improved Scheduling Hw t Reduce Prject Lead Times Thrugh Imprved Scheduling PROBABILISTIC SCHEDULING & BUFFER MANAGEMENT Cnventinal Prject Scheduling ften results in plans that cannt be executed and t many surprises. In many

More information

Hillsborough Board of Education Acceptable Use Policy for Using the Hillsborough Township Public Schools Network

Hillsborough Board of Education Acceptable Use Policy for Using the Hillsborough Township Public Schools Network 2361/Page 1 f 6 Hillsbrugh Bard f Educatin Acceptable Use Plicy fr Using the Hillsbrugh Twnship Public Schls Netwrk It is the gal f the HTPS (Hillsbrugh Twnship Public Schls) Netwrk t prmte educatinal

More information