Due Diligence & Resources
Vendor Management Statement
Bankers’ Bank has a robust vendor management program, where existing vendors are reviewed on a regular basis depending upon 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. The Bank’s vendor management program is routinely examined by both state and federal regulators as well as internal auditors.
For your convenience you may download a single due diligence packet that includes all of the due diligence documents by clicking here. If you are looking for a specific document you can access single documents by clicking on the categories below. To access the content of the due diligence packet or individual documents you must be signed in through the Bank Staff Log In.
ACH Audit (Annual)
Bankers’ Bank is 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. The Auditor’s statement attesting to the completion of the annual audit can be found here.
BSA / AML / CIP
As a chartered and regulated financial institution, Bankers’ Bank maintains 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 auditors, outside auditors and regulators. The bank has 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.
Bankers’ Bank maintains 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. Important information regarding our compliance with the USA PATRIOT Act can be found here.
Bankers’ Bank maintains a comprehensive, risk-based business continuity plan that is regularly tested and revised as required. Customers with access to the restricted areas of this website will find an overview of the plan here (customer only). 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.
Bankers’ Bank has executed agreements with all of its account holders addressing the confidentiality of non-public personal information which may be shared between the bank and its customers.
In addition, all employees of Bankers’ Bank and its subsidiaries sign confidentiality agreements at hire. These agreements limit the types of information that employees may share both within and outside the bank.
Correspondent Concentration - Reg F
Federal Funds, Approved Purchases List
Safety and liquidity are the primary concerns for federal funds activity. The Bankers’ Bank may act as agent for other banks and sell their federal funds to other banks. At least quarterly, the bank conducts regular credit reviews of all approved federal funds purchasers. More frequent review of eligible banks using available market information occurs during times of stress in the banking system. The liability for funds sold as agent remains with the selling respondent banks.
As agent, the Bankers’ Bank determines and selects qualified major banks which meet the Bank’s credit and other criteria. The Bank exercises 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. The current approved Fed Funds list can be found here (customer only).
In June, 2009, the Federal Reserve Bank implemented “limited purpose accounts” called excess balance accounts (EBA’s) to address pressures on correspondent/respondent business relationships in the current market environment.
Bankers’ Bank, as agent, is responsible for managing the EBA account at the Fed on behalf of its customers. These excess funds are a direct liability of the Fed to our customers and considered a “Due from Fed” at the customer level.
FFIEC & Regulatory Guidance
Financial Information - Call Report
Insurance, Employee Bonding and Hiring
Bankers’ Bank maintains Director and Officer insurance coverage and a financial institution bond covering all employees. The bank’s hiring process includes background checks on all new employees. Proof of insurance for the bank can be found here (customer only). Bankers’ Bank also maintains Cyber Liability insurance coverage which can be found here (customer only).
Operational Environment & FIRE Due Diligence
FIRE Communication System SOC 1 Type 1-2019 (customer only)
FIRE SOC Report Bridge Letter 2019 (customer only)
FIRE Website Encryption Document (customer only)
Operational Due Diligence / White Paper (customer only)
Operational Due Diligence / FedWire Testing – 3.14.2020 (customer only)
Summary of Affiliation – Aptys (customer only)
Bankers’ Bank is a bank-owned bank that was formed in 1981. Our 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 are not a requirement.
It is the general practice of Bankers’ Bank not to share our policies beyond our employees, board of directors, auditors and examiners. As a bankers’ bank 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. In addition, 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 that you would like to discuss or review please contact the appropriate area of Bankers’ Bank or your Correspondent Banker.
Regulatory Compliance and Audit
Bankers’ Bank is 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, including an annual external audit, annual BSA/AML audit and a periodic independent IT audit.
Privacy and Information Security
The confidentiality of the non-public information shared with us in the normal course of business is of great concern to Bankers’ Bank. See our Privacy Statement. The bank has 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 by law. Bankers’ Bank is regulated by the Federal Reserve Bank of Chicago, and is subject to a regular series of internal audits, external audits and examinations, including 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, Bankers’ Bank responds 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 telephone calls, e-mails and/or formal written notification, detailing the event and our response.
Unlawful Internet Gambling Enforcement Act (UIGEA)
Bankers’ Bank has implemented policies and procedures to identify and block, prevent or prohibit restricted transactions under UIGEA. The bank is aware of its responsibilities regarding the federally mandated limitations on the use of certain payment mechanisms to complete restricted transactions.