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Quick pointers to ACH and IAT

September 15th, 2009 No comments

Every depository financial institution (DFI) needs to understand the impact of the new rule on its ACH operations regarding OFAC compliance.  DFIs can contract with other parties for ACH processing services but cannot contract away their liabilities and obligations related to OFAC compliance.

Also see, OFAC Compliance Implications

References

  1. There is a letter from the dept of treasury regarding the responsibilities at the bottom of this link
  2. FFIEC guideline before the IAT requirement
  3. OCC (old document again from 2006). See page 8 and 9
  4. NACHA guidelines
  5. NACHA Readiness checklist
  6. ABA Preparedness Checklist
  7. OFAC Letter to NACHA on purely domestic ACH (this is from 1997)

References for corporate

  1. IAT for Corporate practitioners (PPT)
  2. IAT for Corporate Practitioners (Word)
  3. FAQ for Corporate

Resource Centers

  1. NACHA Resource Center
  2. FRB Resource Center

FAQ and Q&A

  1. NACHA FAQ revised 2/27/09
  2. NACHA FAQ for Corporate
  3. NACHA Q&A

Survey

  1. IAT Rediness Survey – FRB
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Idola Announces Aegis, an OFAC Solution for IAT

August 4th, 2009 No comments

Idola Announces Aegis, an OFAC Solution for IAT
08.03.09, 9:00 AM ET

ISELIN, N.J., Aug. 3 /PRNewswire/ — Idola today announced Aegis, a new middleware product that will simplify the process of OFAC screening of International ACH transactions (IAT). New rules issued by NACHA require all international ACH payments to be identified as such, and thus will permit financial institutions to perform due diligence with respect to IAT transactions as required by the Office of Foreign Asset Control (OFAC). These rules become effective September 18, 2009 and will impact all financial initiations that originate or receive ACH transactions.

Aegis, designed based on Service Oriented Architecture (SOA), can intercept and screen both domestic and international ACH messages or mixed source files and can be configured to provide the following functionality:

1. Perform OFAC screening of IAT Transactions or domestic ACH Transactions or both.

2. Operate in “Split Mode”: Segment source file into two files – one containing all transactions without possible OFAC matches and a second one containing suspected matches.

3. Operate in “Highlight Mode”: No modification of source file other than highlighting transactions with any possible matches against scanned lists by setting the secondary screening indicator.

4. Generate a rebalanced file from all transactions cleared after the due diligence review.

5. Real-time or batch mode of operation.

Aegis as a middleware will allow financial institutions the ability to leverage existing workflow procedures and investment in automated OFAC scanning software, by easily integrating with any OFAC screening software. Aegis provides message reconciliation and comprehensive reporting capabilities as mandated by the new IAT regulations.

Aegis will significantly ease the burden of OFAC filtering for financial institutions. More importantly, it will provide transaction identification and routing to assure that all IAT or ACH transactions as required are filtered through OFAC screening software in the shortest possible time.

For further information on how your organization can benefit from Aegis, please contact:

S.K. Murthy IDOLA INFOTECH LLC Tel: 732-744-0066 Ext 202 Fax: 732-744-0061 Email: skmurthy@idolainfotech.com

 About Idola Infotech

 Idola ( http://www.idolainfotech.com ) was founded in 2002 by a team that specialized in software product development and the deployment of complex technology projects. Its management team consists of banking experts, leaders of the regulatory compliance market, and senior technology specialists. Idola has established itself as a leading provider of Risk and Compliance services to the financial sector and has developed commercial products for one of the largest vendors of financial services software. Project management experience has been earned across a wide range of financial institutions from some of the largest in the world to small community banks. Idola has implemented and deployed software solutions domestically and internationally earning its reputation for excellence, reliability, and value.

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‘Save our CEOs’ Teaser for Michael Moore’s New Film

June 14th, 2009 No comments

‘Save our CEOs’ Teaser

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Coca Cola and dangers of BPA

June 10th, 2009 No comments

WASHINGTON, — Environmental Working Group (EWG) today called on The Coca-Cola Company’s chairman and chief executive officer Muhtar Kent to take immediate steps to reduce children’s exposure to bisphenol A (BPA), a toxic chemical used in beverage bottles and beverage can linings.

“Along with hundreds of thousands of Environmental Working Group supporters, I was very disappointed to read reports in The Milwaukee Journal Sentinel and The Washington Post that a Coca-Cola representative joined chemical and food processing company lobbyists in a recent meeting to consider, among other things, the use of “fear tactics” to protect the market for the toxic chemical bisphenol A (BPA),” EWG’s President, Ken Cook wrote Kent.

An internal industry document obtained by journalists and EWG show that a Coca-Cola representative took part in a May 28 food and chemical industry strategy session at Washington’s exclusive Cosmos Club, during which, the document said, “Attendees suggested using fear tactics (e.g. ‘Do you want to have access to baby food anymore?’)” According to the leaked document, “Their ‘holy grail’ spokesperson would be a ‘pregnant young mother who would be willing to speak around the country about the benefits of BPA’.”

“Is this the kind of “marketing” effort that Coca-Cola stands behind when it comes to toxic chemicals that contaminate the food supply?” Cook wrote.

More at EWG…

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New in SQL Server 2005 for Developers (Part 2)

June 10th, 2009 No comments

CROSS APPLY

 

Here is another nice one (CROSS APPLY) and also note the key features here:

Create Function GetOrderDetails(@OrderId Int, @count Int)

      returns table

As

RETURN

      Select top(@count) * from [Order Details]

      Where OrderId = @OrderId

In the above example note the usage of @count in top. I just wanted to show the output of the following statement using the CROSS APPLY statement:

Select * from Orders

Inner join [Order Details] on Orders.OrderId = [order details].OrderId

Check this:

Select O.OrderId, OrderDate, ProductId, UnitPrice, Quantity from orders O

CROSS APPLY

      dbo.GetOrderDetails(O.OrderID, 3) AS D

ORDER BY

      O.OrderId Asc

 

clip_image003

This statement returns all the Orders and only the first three detail records. The APPLY clause acts like a JOIN without the ON clause. Refer to both CROSS APPLY and OUTER Apply here.

 

Event Notification and DDL Triggers

 

This function called Event Notifications is a feature that can be used by applications using SQL Server. This Event notifications executes in response to a variety of Transact-SQL data definition language (DDL) statements and SQL Trace events by sending information about these events to a Service Broker service.

A sample event will be like this:

 

CREATE EVENT NOTIFICATION log_ddl1

   ON SERVER

   FOR ALTER_TABLE

   TO SERVICE ‘//northwind.com/archiveservice’ , ‘current database’;

 

In the above example, ALTER_TABLE is a DDL statement. Refer to DDL Events for Use with Event Notifications for a complete list of DDL Events.

 

Similarly DDL Triggers are a special kind of trigger that fire in response to Data Definition Language (DDL) statements. They can be used to perform administrative tasks in the database such as auditing and regulating database operations. The old DML triggers operate on INSERT, UPDATE, and DELETE statements, and help to enforce business rules and extend data integrity when data is modified in tables or views. DDL triggers operate on CREATE, ALTER, DROP, and other DDL statements. They are used to perform administrative tasks and enforce business rules that affect databases. They apply to all commands of a single type across a database, or across a server.

USE Northwind;

GO

IF EXISTS (SELECT * FROM sys.triggers

    WHERE parent_class = 0 AND name = ‘safety’)

DROP TRIGGER safety

ON DATABASE;

GO

CREATE TRIGGER safety

ON DATABASE

FOR DROP_SYNONYM

AS

   RAISERROR (‘You must disable Trigger “safety” to drop synonyms!’,10, 1)

   ROLLBACK

GO

DROP TRIGGER safety

ON DATABASE;

GO

 

 

 

 

 

Error Handling

 Simply anything can be handled with the TRY/CATCH:

BEGIN TRY

Select 1/0

Select Cast(‘a’ as DateTime)

END TRY

BEGIN CATCH

    SELECT

        ERROR_NUMBER() as ErrorNumber,

        ERROR_MESSAGE() as ErrorMessage;

END CATCH;

 

 

These statements will show the following errors.

clip_image004

clip_image005

 

 

And there is more information about the error also:

    SELECT

        ERROR_NUMBER() AS ErrorNumber,

        ERROR_SEVERITY() AS ErrorSeverity,

        ERROR_STATE() as ErrorState,

        ERROR_LINE () as ErrorLine,

        ERROR_PROCEDURE() as ErrorProcedure,

        ERROR_MESSAGE() as ErrorMessage;

 

 

 

 

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New in SQL Server 2005 for Developers (Part 1)

June 10th, 2009 No comments

May be I’m writing this very late, but will be useful for someone who is looking for features that are introduced in 2005. The content may not be properly formatted as it was prepared in a hurry.

Common Table Expression

A common table expression (CTE) can be thought of as a temporary result set that is defined within the execution scope of a single SELECT, INSERT, UPDATE, DELETE, or CREATE VIEW statement. A CTE is similar to a derived table in that it is not stored as an object and lasts only for the duration of the query. Unlike a derived table, a CTE can be self-referencing and can be referenced multiple times in the same query.

A CTE can be used to:

  • Create a recursive query. For more information, see Recursive Queries Using Common Table Expressions.
  • Substitute for a view when the general use of a view is not required; that is, you do not have to store the definition in metadata.
  • Enable grouping by a column that is derived from a scalar subselect, or a function that is either not deterministic or has external access.
  • Reference the resulting table multiple times in the same statement.

Using a CTE offers the advantages of improved readability and ease in maintenance of complex queries. The query can be divided into separate, simple, logical building blocks. These simple blocks can then be used to build more complex, interim CTEs until the final result set is generated.

Sample (Northwind database):

WITH TopCustomers (City, Cnt)

AS

(

      SELECT City, count(*) FROM customers

      GROUP BY City

      HAVING count(*) > 1

)

SELECT * FROM

      Customers C inner join TopCustomers on C.City = TopCustomers.City

 

TOP function

SQL2005 allows TOP within the sub query also:

— Simple TOP query

SELECT TOP(5) *

FROM Employees;

— Nested TOP query

SELECT *

FROM (SELECT TOP(5) *

      FROM Employees

      ORDER BY [EmployeeId])

AS E

Order by EmployeeId Desc

Pivot Table

Another feature in 2005 is the Pivot table:

 

SELECT ProductId, Sum(Quantity*UnitPrice)

FROM [Order Details]

GROUP BY ProductId;

 clip_image0011

 

The same query as a Pivot table:

WITH Sales(ProductId, SalesAmt)

AS

      (SELECT ProductId, Quantity*UnitPrice

            FROM [Order Details])

SELECT ‘Sales’ AS SalesByProduct, [23], [46], [69], [15], [3]

FROM

      (SELECT ProductId, SalesAmt FROM Sales) AS SourceTable

PIVOT

      (

      SUM(SalesAmt)

      FOR ProductId IN ([23], [46], [69], [15], [3])

      ) AS PivotTable;

 clip_image002

 

Though this doesn’t look very flexible, there will be instances where this can be applicable.

 

 

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ShifD

June 2nd, 2009 No comments

ShifDHow many times have you sent yourself an email or SMS of something you want to remember, like a book or a URL and then it gets lost in your inbox, never to be seen again. With ShifD you can easily send an SMS of a note, place or link that will appear on your computer.

The ShifD website is focused on a simple, clean and friendly design. You can add content with tags that are easily editable. Add a Link to read on your mobile phone later or a note to access from your home computer. Find more about ShifD here.

In its first introduction of a consumer technology solution, The New York Times Company has launched the beta version of  ShifD.  The application, which is accessible on the Web, various mobile devices and on the desktop of Adobe Air, allows users to save links, notes and places.  Users can update and retrieve data through all these platforms.

Above is our interview with Times developers Nick Bilton and Michael Young, who created ShifD.  We taped this piece earlier this week at the Times headquarters.

Read more at New York Times Company Launches ShifD, a Mobile/Web/Desktop Application for Storing Personal Information

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Handbook for buying Compliance Solution

June 2nd, 2009 3 comments

What is Regulatory Compliance?

Regulatory compliance describes the goal that corporations or public agencies aspire to in their efforts to ensure that personnel are aware of and take steps to comply with relevant laws and regulations.

– Wikipedia

In general, compliance means conforming to a specification or policy, standard or law that has been clearly defined.

Compliance in an organization is a cluster of programs, policies and procedures to comply to regulation and can be broadly classified into:

  • BSA/AML Compliance
  • OFAC Compliance
  • IT Compliance
  • E-mail Compliance

The following sections briefly update the BSA part of the compliance.

A Compliance Solution

BSA/AML Functions

Any AML compliance product should be a broader set of the following basic set of features:

  • Customer Due Diligence and Know your Customer refers to customizable policies and procedures of an organization to know the customers with whom they are dealing with. KYC should support different elements based on the organization’s needs.
  • Enhanced Due Diligence refers to the Customer Identification Program mandated by the USA Patriot Act. Tools within the system should allow users to prepare customized questionnaires for customer staging and proper workflow tools to validate.
  • Transaction Monitoring refers to suspicious activity and fraud monitoring on customer transactions which will be mostly by the use of rules according to client need based on BSA laws, regulations and directives. The laws are based on the geographical position of the financial institution and the customer the organization deal with. The function should initiate investigations automatically using the detection mechanism and support easy-to-use tools for a detailed investigation.
  • Case Management and Regulatory Reporting refers to investigation of cases and different methods of reporting the cases to different regulatory authorities.

Common functions

In addition to the above Compliance related feature, the product evaluator from the organization should also have answers to the following questions which mostly apply to any financial software applications.

  • Global audience. Make out a list of countries where the product can be used. Does the product provide compliance to all the regulatory needs for that country?
  • Multi-lingual. Are multiple languages supported? If yes, is multi-language support installation specific? How many languages are supported?
  • User and Rights Management. How are users managed within the application? Does the application use Active Directory? Can the user be given rights based on windows rights?
  • Work flow and Routing mechanisms. How can I create job functions within? How will I assign rights?
  • Batch processing. Will the app allow batch and bulk processing for certain tasks? Is there a list of such processes?
  • Data Import. What are the ways data can be imported? Direct from source systems through channels? Flat files? Database table transformation imports?
  • Information Reporting and Data Export. What are the ways to generate reports? Is there a way to generate reports automatically?
  • Tracing, Logging and Auditing. Does the application support customizable logging to direct to event viewers, flat files, databases and even sinks? Is enough information logged for auditors? For product support are there any trace switches?
  • Licensing. What type of licensing is available? Is there an evaluation version? Can I buy more products in the future?
  • Service and Support. What kind of customer services is provided? What are the terms and conditions?

Platform

In addition to the features, a detailed pre-requisite for the product should be obtained for the product cost statement.

  • Is a dedicated server necessary? What is the Operating System? Are there any limitations in choosing the OS?
  • What platform is it running on? Open source or Proprietary or Legacy? Java or .NET or PHP? Win forms or Web or both? IIS or Apache or Websphere?
  • Is the application dependent on a database? Is that database free? Does the organization already have license for the database? What database edition is required by the product?
  • Is the application using any third-party tool? Is a list of those third-party tools available? Do I need any email clients? How many tools are free? Any particular version? Can those tools be upgraded for free if necessary?
  • Do the end-users require any plug-ins or software to run the application? What is the setup cost for installing that plug-in? Does the end user need to change any browser settings for running scripts, ActiveX, etc?
  • What will be the setup cost? What kind of support is required by the organization for installation?
  • Any task scheduler necessary to run jobs?

Based on the organization’s software policy, a cost sheet can be generated using the following entities.

Features Check-list

AML Product

The following table can be used to check the product feature list before evaluating a product:

Feature

Available Yes/No

Comments

Web based application

Yes / No

List the advantages and disadvantages of having a web or windows based application over the others

Windows based application

Yes / No

Identify if all the features are available in windows or web as a whole. If not list the features that are available in each mode

Customer Due Diligence (CDD)

Yes / No

Risk classification

Yes / No

Customer risk scoring

Yes / No

Risk management

Yes / No

Enhanced Due Diligence (EDD)

Yes / No

Transaction Monitoring

Yes / No

Ready-made rules

Yes / No

Customize rules

Yes / No

Schedule monitoring

Yes / No

Case Management

Yes / No

Case Auditing

Yes / No

Case Investigation

Yes / No

Workflow management

Yes / No

Customize Pages

Yes / No

Selection filters

Yes / No

Regulatory reports

Yes / No

Suspicious Activity Report

Yes / No

Currency Transaction Report

Yes / No

Electronic filing

Yes / No

Custom regulatory reports

Yes / No

Reporting

Yes / No

Export as PDF, Excel, etc

Yes / No

Charts

Yes / No

Platform

The following table will help in putting up together the list of software necessary in addition to the products itself.

Component

Description (list all the required software)

Operating System (in Server)

Database (in Server)

Third Party tools (in Server)

Application Server

Data Access Components and Drivers

Task Schedulers

Office tools

Email client

Supported Browser

File reader

Report viewer

Links

The following pointers can be used for reference. These web links are pointers to the AML and Banking related web sites.

Read more…

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Poor are the most charitable

May 27th, 2009 No comments

Poor give most to charity

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Cool tool !! Folder Size for Windows Explorer

May 7th, 2009 No comments

How many times cleaning the disk clutter becomes a task because folder size is not known, this small utility from a sourceforge project allows it.

Download and execute the utility. Close all windows explorer windows.  On a new explorer, right click on the title bar and choose Folder size as a column to display and wallah!!!!

Folder Size for Windows Explorer

Want your Explorer folders to show sizes of folders and files in the same column like this?

via Folder Size for Windows Explorer.

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