VENDOR MANAGEMENT STATEMENT
We have a robust vendor management program. Existing vendors are reviewed on a regular basis depending on the criticality of the vendor product. Prior to engaging in the services of a new vendor, that vendor is also subject to review based on established parameters. Our program is routinely examined by state and federal regulators, and internal auditors.
DUE DILIGENCE PACKET
Download a single due diligence packet that includes all of the documents.
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ACH Audit (Annual)
We’re a third-party service provider supporting both Originating Depository Financial Institutions (ODFIs) and Receiving Depository Financial Institutions (RDFIs). As indicated in the NACHA Operating Rules, third-party service providers that perform a function of ACH processing on behalf of ODFIs or RDFIs must conduct an annual compliance audit. We have included an Auditor’s statement attesting to the completion of the annual audit below.
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Business Continuity
We maintain a comprehensive, risk-based business continuity plan that is regularly tested and revised as required. The plan includes provisions for contingencies that can be reasonably anticipated including natural disasters, pandemic flu outbreaks and cyber security threats. The plan is reviewed and approved by the bank’s board of directors on an annual basis.
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BSA/AML/CIP
We maintain compliance with all requirements of the Bank Secrecy Act, the USA Patriot Act and other applicable federal law. The adequacy and effectiveness of our BSA/AML compliance program is regularly evaluated by internal and outside auditors, and regulators. We’ve established a BSA officer, BSA-related items are reported as required to the board of directors, and bank-level and department-specific training is conducted annually.
We maintain a written Customer Identification Program (CIP) to confirm the identity of customers, incorporated into the bank’s BSA/AML compliance program and approved by our board of directors.
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Confidentiality
We have executed agreements with all of our account holders addressing the confidentiality of non-public personal information which may be shared between us and our customers.
All of our employees and subsidiaries sign confidentiality agreements at hire. These agreements limit the types of information that our employees share both within and outside the bank.
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Correspondent Concentration – Reg F
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FACT Act & Identity Theft Red Flag Compliance
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Federal Funds, Approved Purchases List
Safety and liquidity are the primary concerns for federal funds activity. We may act as an agent for other banks and sell their federal funds to other banks. At least quarterly, we conduct regular credit reviews of all approved federal funds purchasers. We conduct a more frequent review of eligible banks using available market information during times of stress in the banking system. The liability of funds sold as agent remains with the selling respondent banks.
As your agent, we determine and select qualified major banks which meet our credit and other criteria while exercising the same care in selecting eligible banks as it exercises for its own funds. Banks may be dropped from the approved list as senior management deems appropriate.
In June 2009, the Federal Reserve Bank implemented “limited purpose accounts” called excess balance accounts (EBAs) to address pressures on correspondent/respondent business relationships in the current market environment.
As an agent, we are responsible for managing the EBAs at the Fed on behalf of our customers. These excess funds are a direct liability of the Fed to our customers and considered a “Due from Fed” at the customer level.
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FFIEC and Regulator Guidance
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Financial Information — Call Report
Historical financial information is available at www.ffiec.gov.
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Insurance, Employee Bonding & Hiring
We maintain director and officer insurance coverage, and a financial institution bond coverage on all employees. Our hiring process includes background checks.
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Operational Environment & FIRE Due Diligence
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Ownership
Formed in 1981, we are a bank-owned bank where ownership is independent of control by any group or affiliation. Our stock is not traded on an open exchange. Ownership interests are available to our customers but not a requirement.
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Policy Statement
We do not share our policies beyond our employees, board of directors, auditors and examiners. As a bank for banks, our policies reflect a different operating environment than the majority of retail banks with which we do business, and so would be of limited use to our customers. Also, some bank policies contain information of a sensitive, non-public nature.
This practice may be reviewed on a case by case basis, or as required by law. If there are specific policies you would like to discuss, please feel free to reach out.
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Regulatory and Compliance Audit
We’re a commercial bank examined and regulated by the Federal Reserve Bank of Chicago and the State of Wisconsin Department of Financial Institutions. We comply with all applicable federal and state law, and are subject to a regular regimen of external and internal audits. These include an annual external audit, annual BSA/AML audit and a periodic independent IT audit.
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Privacy and Information Security
The confidentiality of the non-public information shared with us in the normal course of business is of great concern. See our Privacy Statement. We have a comprehensive information security program which is regularly reviewed for completeness and accuracy, and updated as required.
Our response to a data security incident is directed by FFIEC guidance and law. We are regulated by the Federal Reserve Bank of Chicago and are subject to a regular series of internal and external audits, and examinations. This includes reviews of Bank Secrecy Act (BSA) compliance, information security and Gramm Leach Bliley Act (GLBA) compliance, as well as compliance with other applicable laws and regulations.
In the event of a data security event that compromises or potentially compromises non-public customer information, we will respond as required under state and federal law, including requirements of the GLBA. Notification to impacted customer banks and individuals will be in the form of phone calls, e-mails and/or formal written notification detailing the event and our response.
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Unlawful Internet Gambling Enforcement Act (UIGEA)
We have implemented policies and procedures to identify, block, prevent or prohibit restricted transactions under UIGEA. We’re aware of our responsibilities regarding the federally mandated limitations on the use of certain payment mechanisms to complete restricted transactions.
TERMS AND CONDITIONS
EXTERNAL LINKS
ACH Associations
- NACHA – National ACH Association
- SHAZAM, Inc. – Iowa ACH Association
- UMACHA – Upper Midwest ACH Association
- WACHA – Wisconsin ACH Association
Illinois Bank Associations
Indiana Bank Associations
Iowa Bank Associations
Wisconsin Bank Associations
- Wisconsin Bankers Association
- Wisconsin Department of Financial Institutions
- Wisconsin Office of the Commissioner of Insurance
Other Valuable Links
- American Bankers Association
- Conference of State Bank Supervisors
- EMMA – Electronic Municipal Market Access
- FDIC
- Federal Reserve Bank of Chicago
- Federal Reserve Bank of Kansas City
- Federal Reserve Bank of Minneapolis
- Independent Community Bankers of America
- Financial Industry Regulatory Authority
- OFAC – Office of Foreign Assets