6 Months and Counting
Well – we are now a short 6 months away from the Red Flag Guideline compliance date of Nov. 1st. So the question is “where are we at”?
The easy answer it is beginning to be crazy and we see that craziness turning into insanity. In short – there are not enough days left, and the storm has not yet arrived. Most banks have expressed a desire to wait to the last minute to come into compliance. That is a risky proposition, especially as we consider system freezes coming into play in Nov. and Dec.
We are observing everyone beginning to come out of their Gap Analysis – and the vendor selection process beginning. For the biggest banks – this is pretty scary. The typical cycle for vendor selection can be 9-12 months or more! This doesn’t foot. We are seeing htat either these institutions will need to shorten that cycle or deal with the financial impact on the back end as they deploy solutions that allow them to “Get By”.
The community banks and credit unions are better positioned, yet are desiring to “do better”. God bless ’em. We continue to rack our brains about how to get tools in the hands of these 10,000 institutions in an afforable manner.