With scrutiny on lenders’ risk management policies intensifying, more and more community banks are writing their first policies or updating old ones. The OCC just raised the bar for the banks it regulates with the August release of expanded guidelines for environmental risk management that bring their policy requirements in line with those of the FDIC. What are the critical components that should be in every policy? What elements are common to most institution’s policies? How does your institution measure up to industry best practices? How is policy administered across organizations?
Join us for this webinar as seasoned insiders selected from the ranks of a mid-sized bank and small community lender share their experiences in writing and updating environmental policies. Learn what these experts are doing to protect their institutions from environmental risk exposure, and the dangers that lenders face by not have adequate policies in place to protect them from financial and legal liability.
Tuesday, October 29, 2013
2pm EST
75 minutes
Presented by:
Georgina Dannatt
VP, Environmental Risk Manager
Bank of the West
Brian A. Ginter, VP & CCIM
Appraisal/Environmental Group
Burke & Herbert Bank
Larry Schnapf, Attorney, Schnapf Law
Professional ethics in engineering requires managing safety and risk. Engineers have a responsibility to consider how their designs may impact people and to make products as safe as reasonably possible. However, absolute safety is impossible to achieve. Risk is the potential for something harmful to occur, and risk acceptance varies between individuals based on factors like age, experience, and physical condition. Engineers use various methods like testing and simulation to identify risks, analyze them, and find ways to reduce risks to acceptable levels given technical limitations and costs.
Banking operates in a complex system. Key players in the system include the regulators, the banks, and the end customers. They are all in a dance together. The moves of one party have consequences for all the others. Unfortunately, despite good intentions, there is little evidence that of any of the players can actually see the dance they are part of - they only see their own perspective and react accordingly. They are essentially blind to the impact on the whole system.
This short paper explores the themes of the blind dance of regulation. It starts with the flaws in the regulatory paradigm, and discusses the reactions of banks and customers to the regulator’s moves.
Andy Abu-Bakar is a risk management consultant with experience in both the public and private sectors. He discusses how human behavior and biases can influence the effectiveness of risk management processes. He presents two scenarios where behavioral science concepts like commitment escalation and confirmation bias affected risk management. In the first, a project manager rejected unfavorable risk analysis results. In the second, a project team member refused to participate in risk processes. Abu-Bakar argues that leadership must model desired behaviors and implement proper consequences to encourage transparent and collaborative risk management.
The document is a transcript from a webcast presentation titled "It wasn't Raining When Noah Built the Ark!". It introduces the three presenters - Carrie Bekker, Robert Conlon, and Rudy ShouShany - and their respective companies, Bekker Compliance Consulting Partners (BCCP) and Business Continuity Consultancy and Management (BCC Management). The presentation discusses the importance of business continuity management and planning, common myths and statistics around lack of preparation, and the benefits that BCM provides to organizations. It offers the services of the presenters' companies to help attendees create business continuity plans.
Identify, measure, and communicate legal and compliance risk in a whole new way. Lawyers, compliance officers, contract managers, and other legal professionals can discover how to measure and manage legal risk more effectively. "6 Steps to Legal Risk Management" provides practical guidance on developing a risk management framework and adapting it to legal and compliance risk. The approach is based on the internal risk management standard: ISO 31000.
The South East branch was delighted to welcome 'The Risk Doctor', David Hillson, to their latest branch event; this being the 8th Alan Webb memorial lecture. Branch members gathered at Rowfant House in Crawley for the presentation on Wednesday 9th July 2014.
There are many influences when groups make decisions, especially when the decision is perceived to be both risky and important. These influences can be summarised in the “triple strand” of conscious, subconscious and affective factors.
This presentation reports on recent research which has revealed the main drivers of group behaviour in these situations. Understanding and managing these drivers allows groups to make good decisions – find out how. An expanded emotional literacy framework is proposed to enable groups to make good decisions by understanding and managing the underlying influences on group risk attitude.
Crisis Management in Organization Development by The College of Saint Scholas...Atlantic Training, LLC.
The document discusses best practices for crisis management in organizations, including defining different types of crises, conducting risk audits, forming crisis management teams, and outlining the stages of crisis management from detection to recovery. It also examines case studies of real-world crises like the Tylenol poisonings and lessons learned around effective crisis response, communication, and organizational recovery.
Ppt day in the life of a case manager final v 2Robbie Hilson
The document discusses the benefits of having an eDiscovery case manager. It describes how case managers use their extensive training and experience to provide intimate knowledge of cases, customize solutions for each client, and proactively solve problems. Case managers focus on building strong relationships with clients through personalized approaches tailored to each client's needs and skill sets.
Professional ethics in engineering requires managing safety and risk. Engineers have a responsibility to consider how their designs may impact people and to make products as safe as reasonably possible. However, absolute safety is impossible to achieve. Risk is the potential for something harmful to occur, and risk acceptance varies between individuals based on factors like age, experience, and physical condition. Engineers use various methods like testing and simulation to identify risks, analyze them, and find ways to reduce risks to acceptable levels given technical limitations and costs.
Banking operates in a complex system. Key players in the system include the regulators, the banks, and the end customers. They are all in a dance together. The moves of one party have consequences for all the others. Unfortunately, despite good intentions, there is little evidence that of any of the players can actually see the dance they are part of - they only see their own perspective and react accordingly. They are essentially blind to the impact on the whole system.
This short paper explores the themes of the blind dance of regulation. It starts with the flaws in the regulatory paradigm, and discusses the reactions of banks and customers to the regulator’s moves.
Andy Abu-Bakar is a risk management consultant with experience in both the public and private sectors. He discusses how human behavior and biases can influence the effectiveness of risk management processes. He presents two scenarios where behavioral science concepts like commitment escalation and confirmation bias affected risk management. In the first, a project manager rejected unfavorable risk analysis results. In the second, a project team member refused to participate in risk processes. Abu-Bakar argues that leadership must model desired behaviors and implement proper consequences to encourage transparent and collaborative risk management.
The document is a transcript from a webcast presentation titled "It wasn't Raining When Noah Built the Ark!". It introduces the three presenters - Carrie Bekker, Robert Conlon, and Rudy ShouShany - and their respective companies, Bekker Compliance Consulting Partners (BCCP) and Business Continuity Consultancy and Management (BCC Management). The presentation discusses the importance of business continuity management and planning, common myths and statistics around lack of preparation, and the benefits that BCM provides to organizations. It offers the services of the presenters' companies to help attendees create business continuity plans.
Identify, measure, and communicate legal and compliance risk in a whole new way. Lawyers, compliance officers, contract managers, and other legal professionals can discover how to measure and manage legal risk more effectively. "6 Steps to Legal Risk Management" provides practical guidance on developing a risk management framework and adapting it to legal and compliance risk. The approach is based on the internal risk management standard: ISO 31000.
The South East branch was delighted to welcome 'The Risk Doctor', David Hillson, to their latest branch event; this being the 8th Alan Webb memorial lecture. Branch members gathered at Rowfant House in Crawley for the presentation on Wednesday 9th July 2014.
There are many influences when groups make decisions, especially when the decision is perceived to be both risky and important. These influences can be summarised in the “triple strand” of conscious, subconscious and affective factors.
This presentation reports on recent research which has revealed the main drivers of group behaviour in these situations. Understanding and managing these drivers allows groups to make good decisions – find out how. An expanded emotional literacy framework is proposed to enable groups to make good decisions by understanding and managing the underlying influences on group risk attitude.
Crisis Management in Organization Development by The College of Saint Scholas...Atlantic Training, LLC.
The document discusses best practices for crisis management in organizations, including defining different types of crises, conducting risk audits, forming crisis management teams, and outlining the stages of crisis management from detection to recovery. It also examines case studies of real-world crises like the Tylenol poisonings and lessons learned around effective crisis response, communication, and organizational recovery.
Ppt day in the life of a case manager final v 2Robbie Hilson
The document discusses the benefits of having an eDiscovery case manager. It describes how case managers use their extensive training and experience to provide intimate knowledge of cases, customize solutions for each client, and proactively solve problems. Case managers focus on building strong relationships with clients through personalized approaches tailored to each client's needs and skill sets.
An Inside Look at the Challenges Facing Lenders and Appraisers TodayEDR
An Inside Look at the Challenges Facing Lenders and Appraisers Today
June 18, 2014 EDR Web seminar
Regulatory pressures are fundamentally impacting the way that financial institutions manage the appraisal function. Our speakers will tackle the most impactful issues for both lenders and appraisals today. An expert from the Appraisal Institute, the largest appraisal membership society in the world with 23,000+ real estate valuation experts worldwide, will share first-hand research into the challenges faced by appraisers and by lenders that rely on the technical expertise of appraisal services. Attendees will learn about the concerns commercial real estate appraisers face, and the challenges their lender clients face in finding quality appraisers to help them respond to new policies and requirements. Speakers will also share insight into the latest policies from bank regulators like the OCC and FDIC that are impacting the integration of appraisals and environmental risk management. An expert in the trenches of a small community bank will share his insights into the shifting alignment of appraisals and environmental risk management at the community bank level, the importance of having a sound policy in place and actions that banks can take to best prepare for the scrutiny of examiners.
BENEFITS TO AUDIENCE:
- Information on how appraisers can meet today’s top challenges, align their services with the challenges lender clients face
- A deeper understanding of bank regulations impacting appraisals
- An insider’s take on what bank examiners look for
- Advice on steps banks can take to protect themselves against examiner scrutiny
- A look into the forces that are bringing appraisals and environmental due diligence functions closer together
PRESENTED BY:
- Bill Garber, Director of Government and External Relations, Appraisal Institute
- Brian Ginter, Director - Executive Staff, Diversified Real Estate Consulting Network
Vendor Management: How Well Are You Managing Your Consultants and Appraisers?EDR
This document provides guidance on managing third party vendors for appraisals and environmental reviews. It discusses establishing policies and procedures for vendor selection, contracting, ongoing monitoring and reviews. Key recommendations include having independent job managers to avoid undue influence, selecting the most qualified vendor for each complex assignment, providing constructive feedback to vendors, and optimizing the bidding process to spread work among competent peers and maintain independence. The goal is to meet regulatory expectations for managing risks from third party vendors.
The document discusses guidelines for developing an effective environmental risk management policy. It recommends that banks assess their risk appetite and the types of lending and collateral typically involved to determine what the policy should include. The key elements of an effective policy are roles and responsibilities, personnel training, types of properties covered, a tiered approach to environmental due diligence based on risk levels, ongoing monitoring, and qualifications for approved environmental professionals. Developing thresholds for different levels of environmental due diligence based on risk factors like loan size, property type and location is an important but complex part of the policy. The policy should be reviewed annually and updated as needed to ensure it continues meeting the bank's needs.
Pg. 04Question Four Assignment 1Deadline Day 21.docxmattjtoni51554
Pg. 04
Question Four
Assignment 1
Deadline: Day 21/10/2017 @ 23:59
[Total Mark for this Assignment is 5]
Decision support systems
IT 445
College of Computing and Informatics
Question One
1 Mark
Learning Outcome(s):
Instructors: State the Learning Outcome(s) that match this question
Explain how decision style can effect on the decision makers think and react to a problem?
Question Two
2 Marks
Learning Outcome(s):
Instructors: State the Learning Outcome(s) that match this question
Explain of closed-loop Cycle business performance management methodology and its four processes in detail.Question Three
1 Mark
Learning Outcome(s):
Instructors: State the Learning Outcome(s) that match this question
What are the major categories that classified the managers’ roles? Explain the following roles and match them with their categories (Negotiator, Leader, Spokesperson, and Entrepreneur)?
Question Four
1 Mark
Learning Outcome(s):
Instructors: State the Learning Outcome(s) that match this question
Explain and draw the architecture of web-based data warehousing.
What are ethics?
Ethics is a cumulative effort to understand and to control individualism (or existentialism).
Necessary to control this self-regarding human characteristic to live peacefully as an extended group of people.
Ethical behaviour =balance between self-interest and group responsibility.
It is largely a learned skill, rather than an instinct.
Ethics = informal guide to professional decision-making with clear moral guidelines.
The Concept of Engineering Ethics
Ethics is a study of morality in practice
Ethics is given relevance as the application of moral values, particularly in a professional capacity.
2
Ethics =provision of a value system
Very often a guide to proper conduct in society/ work place, rather than imposition of a set of rules like the Road Code
It enables professionals to be influenced and guided in their decision making
Ethical guidelines can very often be informative and descriptive, rather than authoritarian and prescriptive
Values, Etiquette, Morals and Ethics
Values: Your own subjective principles including worth and desirability
Etiquette: Considered good mannered and polite
Morality: Applying a set of morally correct/ honourable set of rules/ principles to situation
Morality = generally accepted standards of right and wrong in a society
Ethics = study of moral decision-making
Used when referring to professional behaviour
Can appear in a code of professional ethics
In New Zealand
A code of engineering ethics is published by IPENZ, which is the professional body, representing professional engineers from all disciplines in New Zealand.
The ethical objectives of the institution are to develop and promote ethical engineering practices benefiting the wider community.
Which is particularly appropriate for engineers, and which is published for the information of the public.
These ethical values .
The document discusses risk management in the public sector. It defines risk as the uncertainty of outcome, whether positive or negative, of actions and events. It describes evaluating risks based on likelihood and impact. Challenges for the public sector include increased complexity, partnerships, expectations and media attention. Risk management must consider strategic, operational, financial, behavioral and other categories of risk. Performance reporting should include risk information.
This document discusses several approaches to ethical decision making, including stakeholder impact analysis and traditional decision-making frameworks. It outlines a stakeholder impact analysis framework that involves identifying stakeholders, evaluating quantifiable and non-quantifiable impacts, and assessing fairness and rights. It also describes three traditional decision-making approaches: the 5-question approach, moral standards approach, and Pastin's approach. The document provides guidance on using these frameworks to evaluate options and make ethical decisions.
Protect the rights of the client when delivering services
Use effective problem solving techniques when exposed to competing value systems
Ensure services are available to all clients regardless of personal values, beliefs, attitudes and culture
Recognise potential ethical issues and ethical dilemmas in the workplace and discuss with an appropriate person
Recognise unethical conduct and report to an appropriate person
Work within boundaries and constraints applicable to work role
Demonstrate effective application of guidelines and legal requirements relating to disclosure and confidentiality
Demonstrate awareness of own personal values and attitudes and take into account to ensure non-judgmental practice
Recognise, avoid and/or address any conflict of interest
Summary
Additional resources
The Importance Of Environmental QualityAmanda Brady
The document discusses environmental inequalities in urban environments. It argues that while environmental inequalities exist in France, there is a lack of political will to address the issue. The country's historical technical and normative approaches to the environment have hindered recognizing these inequalities. International approaches that link social and environmental issues could provide alternative frameworks for understanding environmental justice. Overall, the document examines how France can better identify and address environmental inequalities in cities.
This document provides an agenda and overview of a workshop on ISO 31000 (Nov. 2009) for risk management. The agenda covers defining risk, adopting the ISO 31000 framework, an overview of the framework including principles and process, selling enterprise risk management to senior management, using risk appetite and risk matrices, integrating risk management practices, and next steps for implementation and measurement. The workshop aims to explain the key aspects of the new ISO 31000 standard and how to implement an effective risk management program based on this international standard.
Project Charter template (contains Scope Section) project nameExe.docxstilliegeorgiana
Project Charter template (contains Scope Section): project name:Executive Summary
Where did this project come from?
Why is it being done?
What impact will the project create (internally, externally)?
What strategic plan does it contribute to?
What does the customer receive/not receive by project end?
What key assumptions are driving this project?
What risks could challenge project success?Goals
What business/organization goal(s) does this project support?
What business need is being satisfied by this project?Objectives
What, specifically, needs to be done to meet project/customer requirements/expectations/goal?
What is the target of the project?
Note: Ensure each objective contributes to the goal. Check to satisfy the "SMART" criteriaScope:
What does the work of the project to meet goal include/not include?Work IncludesWork does not IncludePhases ⁄ Deliverables:
What are the major components of work to meet the goals/objectives/scope?
What are the customer, process, and project deliverables within each phase?
Phase
Description of Phase
Deliverables
Internal
External
Assumptions:
What unknowns are being made known in this project?
What uncertainties are considered true, real, or certain for planning purposes?
What trial balloons are being floated to verify information?
Assumption
Rationale
Probability of Assumption being True
Impact to Project if Assumption is not True
Risks:
What events could jeopardize this project's success?
Risk
Supporting Detail (Analysis to be continued in Risk Management Plan/ Register)
Constraints:
What is restricting this project?
What standards, regulations, technologies, resource availability impact this project?
Constraint
Supporting Detail
Initial Project SizingBudget:
What are the estimated costs to complete this project (document variability, range, precision at this point)
What is the financial justification for this project?
(i.e. Benefit Cost Analysis, Return on Investment, NPV . . .)
What financial gains are there to doing/not doing this project?High Level Schedule:
When are the phases/deliverables planned to begin/end?
Phase/Deliverable
Time
Milestones:
What major points are important to communicate/measure against?
When should/will they occur?Resource Requirements:
What specialized resources are necessary to complete this project?
Team Member
Role
Responsibility
Sponsor
Project Manager
Management Approaches:
How will status be taken?
How will project be communicated?
How will change be managed?
How will issues be escalated?
How will the risk be managed?
Communication Type
Stakeholders
Frequency
Agenda/ Content
Responsible
Distribution Media
Note: These may be separate plans within the context of the integrated project planSign-offs/Reviews:
At what points will management/customer/team/peer reviews be conducted? For what ...
The document outlines the risk management process used at a university. It consists of 6 steps: 1) Establish the context by defining objectives and stakeholders, 2) Identify risks and how they could occur, 3) Analyze risks by evaluating existing controls and likelihood and impact, 4) Evaluate risks to determine if they are acceptable, 5) Treat risks by reducing likelihood or impact or other options, and 6) Monitor and review the risk management process. The goal is to properly manage risks to help the university achieve its strategic goals and successfully execute operations.
The document discusses the steps involved in decision making. It begins by defining decision making as the selection of a course of action from alternatives. It then outlines 8 steps in the decision making process: 1) identifying the problem, 2) gathering information, 3) establishing principles for evaluation, 4) brainstorming alternatives, 5) evaluating alternatives, 6) selecting the best alternative, 7) executing the decision, and 8) evaluating results. Each step is then discussed in more detail, outlining techniques and best practices for effective decision making.
The document outlines the key steps in the decision making process: 1) Recognizing the problem, 2) Identifying the objective of the decision, 3) Gathering and evaluating relevant data, 4) Listing and evaluating alternative courses of action, 5) Selecting the best alternative, 6) Implementing the decision, and 7) Gathering feedback. It emphasizes that decision making involves tradeoffs between alternatives that are rarely clearly right or wrong. Managers must make decisions despite uncertainty and rely on others while ultimately being responsible. The process described aims to help managers select a desirable course of action to provide solutions to problems.
The document discusses the challenges of risk management for projects and public sector organizations. It provides examples of complex projects like the Terminal 5 project at Heathrow airport and challenges faced by the London Development Agency and London Underground. It also discusses how risk management is evolving from a technical process to one that considers social and behavioral factors.
Crisis Management and Protecting Your ReputationTiffanyMiller57
This presentation by Partner Julie Davis of James E. Arnold & Associates, LPA outlines crisis management and protecting your reputation. The presentation was originally shared at The Ohio Society of CPAs 2017 Columbus Accounting Show.
http://arnlaw.com
This document discusses options for conducting environmental due diligence when assessing commercial real estate loans. It describes 5 common tools that lenders use to mitigate environmental risk: 1) Phase I environmental site assessments, 2) transaction screen assessments, 3) desktop reviews of government records, 4) environmental questionnaires, and 5) environmental indemnification agreements. It provides details on the process and costs involved with each tool. It recommends that lenders have clear guidelines in their environmental policies for determining which tool is appropriate for a given loan based on factors like loan size, perceived risk level, and property type. The goal is to balance performing sufficient due diligence with conserving time and money.
This document introduces a self-assessment survey tool to help businesses evaluate security risks and identify areas for improvement. The survey consists of 30 questions divided into four sections addressing main risks, community engagement, security measures, and security management. Businesses are encouraged to complete the survey annually and prioritize addressing lower scores. Completing the survey is the first step, with optional accreditation also available through the Secured Environments Scheme. Frequently asked questions provide guidance, such as how to respond if unsure of an answer or if a statement does not apply.
Grady L. Shields provides legal advice on how underwriting needs to change in today's market. Underwriters should look beyond just price and consider non-scope issues like asbestos. They should also take property condition assessments and potential compliance issues into account as these could threaten a borrower's ability to pay or expose the lender to liability. Underwriters must make it clear borrowers cannot rely on the lender's due diligence. Post-loan, lenders should follow up on issues like brownfields remediation and conduct risk-based due diligence for refinancings.
This document discusses the potential impacts of the Trump administration on brownfield site cleanup and redevelopment. Key points include: regulatory and budget uncertainty at the federal level; proposed cuts to EPA and other agency budgets that support brownfields work; the emphasis on devolving programs to states and private partnerships; and opportunities through continued tax incentives and bipartisan interest in Congress to enhance existing brownfield programs. Overall the outlook presents challenges but also opportunities if state, local, and private actors can help fill gaps in federal support.
More Related Content
Similar to Learn From the Experts: Critical Elements of Effective Environmental Policies
An Inside Look at the Challenges Facing Lenders and Appraisers TodayEDR
An Inside Look at the Challenges Facing Lenders and Appraisers Today
June 18, 2014 EDR Web seminar
Regulatory pressures are fundamentally impacting the way that financial institutions manage the appraisal function. Our speakers will tackle the most impactful issues for both lenders and appraisals today. An expert from the Appraisal Institute, the largest appraisal membership society in the world with 23,000+ real estate valuation experts worldwide, will share first-hand research into the challenges faced by appraisers and by lenders that rely on the technical expertise of appraisal services. Attendees will learn about the concerns commercial real estate appraisers face, and the challenges their lender clients face in finding quality appraisers to help them respond to new policies and requirements. Speakers will also share insight into the latest policies from bank regulators like the OCC and FDIC that are impacting the integration of appraisals and environmental risk management. An expert in the trenches of a small community bank will share his insights into the shifting alignment of appraisals and environmental risk management at the community bank level, the importance of having a sound policy in place and actions that banks can take to best prepare for the scrutiny of examiners.
BENEFITS TO AUDIENCE:
- Information on how appraisers can meet today’s top challenges, align their services with the challenges lender clients face
- A deeper understanding of bank regulations impacting appraisals
- An insider’s take on what bank examiners look for
- Advice on steps banks can take to protect themselves against examiner scrutiny
- A look into the forces that are bringing appraisals and environmental due diligence functions closer together
PRESENTED BY:
- Bill Garber, Director of Government and External Relations, Appraisal Institute
- Brian Ginter, Director - Executive Staff, Diversified Real Estate Consulting Network
Vendor Management: How Well Are You Managing Your Consultants and Appraisers?EDR
This document provides guidance on managing third party vendors for appraisals and environmental reviews. It discusses establishing policies and procedures for vendor selection, contracting, ongoing monitoring and reviews. Key recommendations include having independent job managers to avoid undue influence, selecting the most qualified vendor for each complex assignment, providing constructive feedback to vendors, and optimizing the bidding process to spread work among competent peers and maintain independence. The goal is to meet regulatory expectations for managing risks from third party vendors.
The document discusses guidelines for developing an effective environmental risk management policy. It recommends that banks assess their risk appetite and the types of lending and collateral typically involved to determine what the policy should include. The key elements of an effective policy are roles and responsibilities, personnel training, types of properties covered, a tiered approach to environmental due diligence based on risk levels, ongoing monitoring, and qualifications for approved environmental professionals. Developing thresholds for different levels of environmental due diligence based on risk factors like loan size, property type and location is an important but complex part of the policy. The policy should be reviewed annually and updated as needed to ensure it continues meeting the bank's needs.
Pg. 04Question Four Assignment 1Deadline Day 21.docxmattjtoni51554
Pg. 04
Question Four
Assignment 1
Deadline: Day 21/10/2017 @ 23:59
[Total Mark for this Assignment is 5]
Decision support systems
IT 445
College of Computing and Informatics
Question One
1 Mark
Learning Outcome(s):
Instructors: State the Learning Outcome(s) that match this question
Explain how decision style can effect on the decision makers think and react to a problem?
Question Two
2 Marks
Learning Outcome(s):
Instructors: State the Learning Outcome(s) that match this question
Explain of closed-loop Cycle business performance management methodology and its four processes in detail.Question Three
1 Mark
Learning Outcome(s):
Instructors: State the Learning Outcome(s) that match this question
What are the major categories that classified the managers’ roles? Explain the following roles and match them with their categories (Negotiator, Leader, Spokesperson, and Entrepreneur)?
Question Four
1 Mark
Learning Outcome(s):
Instructors: State the Learning Outcome(s) that match this question
Explain and draw the architecture of web-based data warehousing.
What are ethics?
Ethics is a cumulative effort to understand and to control individualism (or existentialism).
Necessary to control this self-regarding human characteristic to live peacefully as an extended group of people.
Ethical behaviour =balance between self-interest and group responsibility.
It is largely a learned skill, rather than an instinct.
Ethics = informal guide to professional decision-making with clear moral guidelines.
The Concept of Engineering Ethics
Ethics is a study of morality in practice
Ethics is given relevance as the application of moral values, particularly in a professional capacity.
2
Ethics =provision of a value system
Very often a guide to proper conduct in society/ work place, rather than imposition of a set of rules like the Road Code
It enables professionals to be influenced and guided in their decision making
Ethical guidelines can very often be informative and descriptive, rather than authoritarian and prescriptive
Values, Etiquette, Morals and Ethics
Values: Your own subjective principles including worth and desirability
Etiquette: Considered good mannered and polite
Morality: Applying a set of morally correct/ honourable set of rules/ principles to situation
Morality = generally accepted standards of right and wrong in a society
Ethics = study of moral decision-making
Used when referring to professional behaviour
Can appear in a code of professional ethics
In New Zealand
A code of engineering ethics is published by IPENZ, which is the professional body, representing professional engineers from all disciplines in New Zealand.
The ethical objectives of the institution are to develop and promote ethical engineering practices benefiting the wider community.
Which is particularly appropriate for engineers, and which is published for the information of the public.
These ethical values .
The document discusses risk management in the public sector. It defines risk as the uncertainty of outcome, whether positive or negative, of actions and events. It describes evaluating risks based on likelihood and impact. Challenges for the public sector include increased complexity, partnerships, expectations and media attention. Risk management must consider strategic, operational, financial, behavioral and other categories of risk. Performance reporting should include risk information.
This document discusses several approaches to ethical decision making, including stakeholder impact analysis and traditional decision-making frameworks. It outlines a stakeholder impact analysis framework that involves identifying stakeholders, evaluating quantifiable and non-quantifiable impacts, and assessing fairness and rights. It also describes three traditional decision-making approaches: the 5-question approach, moral standards approach, and Pastin's approach. The document provides guidance on using these frameworks to evaluate options and make ethical decisions.
Protect the rights of the client when delivering services
Use effective problem solving techniques when exposed to competing value systems
Ensure services are available to all clients regardless of personal values, beliefs, attitudes and culture
Recognise potential ethical issues and ethical dilemmas in the workplace and discuss with an appropriate person
Recognise unethical conduct and report to an appropriate person
Work within boundaries and constraints applicable to work role
Demonstrate effective application of guidelines and legal requirements relating to disclosure and confidentiality
Demonstrate awareness of own personal values and attitudes and take into account to ensure non-judgmental practice
Recognise, avoid and/or address any conflict of interest
Summary
Additional resources
The Importance Of Environmental QualityAmanda Brady
The document discusses environmental inequalities in urban environments. It argues that while environmental inequalities exist in France, there is a lack of political will to address the issue. The country's historical technical and normative approaches to the environment have hindered recognizing these inequalities. International approaches that link social and environmental issues could provide alternative frameworks for understanding environmental justice. Overall, the document examines how France can better identify and address environmental inequalities in cities.
This document provides an agenda and overview of a workshop on ISO 31000 (Nov. 2009) for risk management. The agenda covers defining risk, adopting the ISO 31000 framework, an overview of the framework including principles and process, selling enterprise risk management to senior management, using risk appetite and risk matrices, integrating risk management practices, and next steps for implementation and measurement. The workshop aims to explain the key aspects of the new ISO 31000 standard and how to implement an effective risk management program based on this international standard.
Project Charter template (contains Scope Section) project nameExe.docxstilliegeorgiana
Project Charter template (contains Scope Section): project name:Executive Summary
Where did this project come from?
Why is it being done?
What impact will the project create (internally, externally)?
What strategic plan does it contribute to?
What does the customer receive/not receive by project end?
What key assumptions are driving this project?
What risks could challenge project success?Goals
What business/organization goal(s) does this project support?
What business need is being satisfied by this project?Objectives
What, specifically, needs to be done to meet project/customer requirements/expectations/goal?
What is the target of the project?
Note: Ensure each objective contributes to the goal. Check to satisfy the "SMART" criteriaScope:
What does the work of the project to meet goal include/not include?Work IncludesWork does not IncludePhases ⁄ Deliverables:
What are the major components of work to meet the goals/objectives/scope?
What are the customer, process, and project deliverables within each phase?
Phase
Description of Phase
Deliverables
Internal
External
Assumptions:
What unknowns are being made known in this project?
What uncertainties are considered true, real, or certain for planning purposes?
What trial balloons are being floated to verify information?
Assumption
Rationale
Probability of Assumption being True
Impact to Project if Assumption is not True
Risks:
What events could jeopardize this project's success?
Risk
Supporting Detail (Analysis to be continued in Risk Management Plan/ Register)
Constraints:
What is restricting this project?
What standards, regulations, technologies, resource availability impact this project?
Constraint
Supporting Detail
Initial Project SizingBudget:
What are the estimated costs to complete this project (document variability, range, precision at this point)
What is the financial justification for this project?
(i.e. Benefit Cost Analysis, Return on Investment, NPV . . .)
What financial gains are there to doing/not doing this project?High Level Schedule:
When are the phases/deliverables planned to begin/end?
Phase/Deliverable
Time
Milestones:
What major points are important to communicate/measure against?
When should/will they occur?Resource Requirements:
What specialized resources are necessary to complete this project?
Team Member
Role
Responsibility
Sponsor
Project Manager
Management Approaches:
How will status be taken?
How will project be communicated?
How will change be managed?
How will issues be escalated?
How will the risk be managed?
Communication Type
Stakeholders
Frequency
Agenda/ Content
Responsible
Distribution Media
Note: These may be separate plans within the context of the integrated project planSign-offs/Reviews:
At what points will management/customer/team/peer reviews be conducted? For what ...
The document outlines the risk management process used at a university. It consists of 6 steps: 1) Establish the context by defining objectives and stakeholders, 2) Identify risks and how they could occur, 3) Analyze risks by evaluating existing controls and likelihood and impact, 4) Evaluate risks to determine if they are acceptable, 5) Treat risks by reducing likelihood or impact or other options, and 6) Monitor and review the risk management process. The goal is to properly manage risks to help the university achieve its strategic goals and successfully execute operations.
The document discusses the steps involved in decision making. It begins by defining decision making as the selection of a course of action from alternatives. It then outlines 8 steps in the decision making process: 1) identifying the problem, 2) gathering information, 3) establishing principles for evaluation, 4) brainstorming alternatives, 5) evaluating alternatives, 6) selecting the best alternative, 7) executing the decision, and 8) evaluating results. Each step is then discussed in more detail, outlining techniques and best practices for effective decision making.
The document outlines the key steps in the decision making process: 1) Recognizing the problem, 2) Identifying the objective of the decision, 3) Gathering and evaluating relevant data, 4) Listing and evaluating alternative courses of action, 5) Selecting the best alternative, 6) Implementing the decision, and 7) Gathering feedback. It emphasizes that decision making involves tradeoffs between alternatives that are rarely clearly right or wrong. Managers must make decisions despite uncertainty and rely on others while ultimately being responsible. The process described aims to help managers select a desirable course of action to provide solutions to problems.
The document discusses the challenges of risk management for projects and public sector organizations. It provides examples of complex projects like the Terminal 5 project at Heathrow airport and challenges faced by the London Development Agency and London Underground. It also discusses how risk management is evolving from a technical process to one that considers social and behavioral factors.
Crisis Management and Protecting Your ReputationTiffanyMiller57
This presentation by Partner Julie Davis of James E. Arnold & Associates, LPA outlines crisis management and protecting your reputation. The presentation was originally shared at The Ohio Society of CPAs 2017 Columbus Accounting Show.
http://arnlaw.com
This document discusses options for conducting environmental due diligence when assessing commercial real estate loans. It describes 5 common tools that lenders use to mitigate environmental risk: 1) Phase I environmental site assessments, 2) transaction screen assessments, 3) desktop reviews of government records, 4) environmental questionnaires, and 5) environmental indemnification agreements. It provides details on the process and costs involved with each tool. It recommends that lenders have clear guidelines in their environmental policies for determining which tool is appropriate for a given loan based on factors like loan size, perceived risk level, and property type. The goal is to balance performing sufficient due diligence with conserving time and money.
This document introduces a self-assessment survey tool to help businesses evaluate security risks and identify areas for improvement. The survey consists of 30 questions divided into four sections addressing main risks, community engagement, security measures, and security management. Businesses are encouraged to complete the survey annually and prioritize addressing lower scores. Completing the survey is the first step, with optional accreditation also available through the Secured Environments Scheme. Frequently asked questions provide guidance, such as how to respond if unsure of an answer or if a statement does not apply.
Similar to Learn From the Experts: Critical Elements of Effective Environmental Policies (20)
Grady L. Shields provides legal advice on how underwriting needs to change in today's market. Underwriters should look beyond just price and consider non-scope issues like asbestos. They should also take property condition assessments and potential compliance issues into account as these could threaten a borrower's ability to pay or expose the lender to liability. Underwriters must make it clear borrowers cannot rely on the lender's due diligence. Post-loan, lenders should follow up on issues like brownfields remediation and conduct risk-based due diligence for refinancings.
This document discusses the potential impacts of the Trump administration on brownfield site cleanup and redevelopment. Key points include: regulatory and budget uncertainty at the federal level; proposed cuts to EPA and other agency budgets that support brownfields work; the emphasis on devolving programs to states and private partnerships; and opportunities through continued tax incentives and bipartisan interest in Congress to enhance existing brownfield programs. Overall the outlook presents challenges but also opportunities if state, local, and private actors can help fill gaps in federal support.
The document discusses several business trends for 2017 and beyond, including the rise of millennials, increased automation through technologies like artificial intelligence, trends in urbanization like more companies moving to cities, and the growth of smart cities. It notes key facts about each trend, such as the large size of the millennial population compared to Gen X, the types of jobs that may be automated, how technologies are accelerating mass adoption, and examples of smart city initiatives in areas like transportation, housing, and energy infrastructure.
This document discusses trichloroethylene (TCE) and the risks it poses. It notes that studies have shown TCE in indoor air can harm fetal development, especially during the first trimester of pregnancy. Short term exposure to even low doses of TCE may also present acute hazards. The EPA has proposed limiting TCE use under the Toxic Substances Control Act due to these risks. TCE was formerly used in many consumer products like adhesives, paint strippers, and spot removers. Disclosing TCE risks to tenants can be difficult and monitoring indoor air quality may be needed if subslab levels are high.
The document summarizes key points from a presentation by Robert Parson on real estate appraisals and evaluations from an examiner's viewpoint. It outlines the regulatory framework for appraisals, including the importance of competency over licensure. It also discusses target exam areas such as the selection process, determining when an appraisal is "stale", the business loan exemption, and managing the appraisal threshold. Additionally, it covers the definition and requirements of evaluations, including that they must provide market value and sufficient analysis. Lastly, it stresses that reviews and evaluations should be conducted by competent individuals in a process-driven manner.
The document summarizes key points from a presentation by Robert Parson on real estate appraisals and evaluations from an examiner's viewpoint. It outlines the regulatory framework for appraisals, including the importance of competency over licensure. It also discusses target exam areas such as the selection process, independence, and when appraisals become stale. Additionally, it covers the differences between appraisals, evaluations, and other valuation categories, and emphasizes that evaluations and reviews should be processes conducted by competent individuals rather than simply filling out forms.
This document discusses navigating the commercial real estate technology landscape. It outlines various technology solutions for tasks like loan approval, market intelligence, portfolio management, risk analysis. These include data aggregators, crowd-sourced platforms, workflow and CRM tools. The document also discusses how these solutions have developed from early internet listing services and how full integration of available data sources may shape the future of CRE technology.
This document discusses establishing an effective compliance program at commercial lenders. It notes the intense pressure for cost reduction and revenue growth that requires a coordinated compliance risk management system. An effective program has elements like qualified compliance staff, risk testing, documentation, and addressing regulatory changes. Key elements include compliance resources, testing, responsibility, policies, communication, training, technology, issue reporting, and adapting to new laws. The document provides sources for further information on preparing for and passing regulatory exams and compliance program best practices.
The document discusses strategies for accelerating growth in the environmental consulting industry through organic growth and mergers and acquisitions (M&A). It notes that the global market for environmental consulting services is expected to double to $100 billion by 2020. For companies to achieve strong growth, they need a strategic focus on land, infrastructure, water and energy. Both organic growth and M&A are important, as M&A provides immediate access to new markets and expertise, while organic growth is slow. The document provides tips for companies developing strategic growth plans and M&A strategies.
The document summarizes market trends in Charlotte, North Carolina. It finds that the Charlotte region continues to experience population and job growth, with over 100 people moving to the area each day. This growth is driven by relocations for new jobs and employment opportunities, especially among young professionals. Office and apartment demand remains strong, particularly in urban and transit-accessible areas of downtown and surrounding neighborhoods. While much of the growth has benefited the Charlotte region, some suburban areas further from jobs and transit are struggling to attract commercial investment and pay for rising infrastructure costs from new households.
The document summarizes market trends in Charlotte, North Carolina. It finds that the Charlotte region continues to experience population and job growth, with over 100 new residents moving in daily. Office and apartment demand remains strong, driven by household growth and an expanding job market concentrated in technology. However, growth is uneven across the region, with some suburban areas struggling to attract jobs and development. The document suggests Charlotte is following national trends of preferring mixed-use, transit-accessible development that integrates living, working, and recreation.
The document discusses trends in retail, including the closing of stores in Q1 2017 but growth in some areas. It identifies 6 retailers expanding through both online and physical stores. Reasons internet retailers open stores include customers preferring to see/feel items and convenience. Online retailers have advantages like customer data and brand loyalty. Both online and physical retailers are combining channels to provide an omni-channel experience.
This document discusses trends in e-commerce growth and its impact on the industrial real estate market. Some key points:
- E-commerce's share of total US retail sales has steadily increased since 2011 and reached 10.8% in 2015.
- The top e-commerce markets from 2010-2016 were the Inland Empire and Dallas/Fort Worth, reflecting increased demand for fulfillment centers.
- E-commerce is generating demand for new types of industrial buildings like mega fulfillment centers, parcel hubs, and last-mile delivery centers.
- Major retailers are expanding their industrial footprints to accommodate growing e-commerce operations and inventory needs.
This document summarizes a panel discussion on trends in the commercial real estate finance industry. It discusses current market trends such as declining transaction volumes and shifts among lenders. Regulatory topics covered include potential reforms to Dodd-Frank and the future of Fannie Mae and Freddie Mac. The panel also examines potential impacts of infrastructure spending, tax reform proposals, and changes to risk retention rules on the commercial real estate finance market. Attendees were surveyed on their preferences for various options for GSE reform related to multifamily lending.
This document discusses the need for Interagency Environmental Guidelines (IEG) similar to the existing Interagency Appraisal Guidelines (IAG). It argues that just as IAG established standards for appraiser competence, independence, and report content for federally-related real estate transactions, IEG are overdue to establish similar standards for environmental professionals and reports. Several issues are identified that could be addressed through IEG, such as defining environmental professional qualifications, establishing standards for different types of environmental reports, and identifying high-risk property types requiring environmental assessments. The lack of IEG is described as a "weak link" in the real estate lending process.
This document discusses the potential impacts of the Trump administration on brownfield site cleanup and redevelopment. Key points include: regulatory and budget uncertainty at the federal level; proposed cuts to EPA and other agency budgets that support brownfields work; the emphasis on devolving programs to states and private partnerships; and opportunities through ongoing congressional interest in brownfields legislation and existing tax incentives. While federal funding sources face cuts, states, local groups, and private industry will play a bigger role in driving brownfield redevelopment under the new administration's priorities.
The document discusses the impact that the Trump administration may have on brownfield site cleanup and redevelopment. It notes regulatory uncertainty and anticipated cuts to federal funding programs that have supported brownfield work. Specifically, the Trump budget proposes eliminating or significantly reducing funding for the EPA, HUD, EDA, and other agencies involved in brownfield funding. It also discusses congressional efforts to introduce brownfield reauthorization and funding bills. The document advises public-private partnerships and integrating brownfields into new areas like manufacturing and sustainable materials management will be important for continuing redevelopment work in the current climate.
The document summarizes key points from a presentation by Robert Parson on real estate appraisals and evaluations from an examiner's viewpoint. It outlines the regulatory framework for appraisals, including the importance of competency over licensure. It also discusses target exam areas such as the selection process, independence, and when appraisals become stale. Additionally, it covers the differences between appraisals, evaluations, and other valuation categories, and emphasizes that evaluations and reviews should be processes conducted by competent individuals, not just forms.
The document discusses the state of commercial real estate markets globally and in various regions. It notes that demand in London began tapering off in 2016 and availability is at a 10-year average. Investment volumes in London were down 19% in 2016. The outlook predicts more stable investment activity globally in 2017 compared to 2016, with London, Berlin, and Sydney among the top target cities. Geopolitical events have impacts but economic cycles are more important long-term drivers of real estate markets.
This document discusses case studies related to REC, HREC, and CREC determinations. It presents six hypothetical cases involving different properties and prior uses, and poses questions to a panel of experts about whether each case represents a REC, HREC, or CREC based on the definitions in the E1527-13 standard. The cases involve issues such as a former dry cleaner, gas stations, industrial usage, and more. The panelists provide their opinions on the classification for each case. The document also reviews the relationship between RECs, HRECs, and CRECs.
Calculation of compliance cost: Veterinary and sanitary control of aquatic bi...Alexander Belyaev
Calculation of compliance cost in the fishing industry of Russia after extended SCM model (Veterinary and sanitary control of aquatic biological resources (ABR) - Preparation of documents, passing expertise)
How to Invest in Cryptocurrency for Beginners: A Complete GuideDaniel
Cryptocurrency is digital money that operates independently of a central authority, utilizing cryptography for security. Unlike traditional currencies issued by governments (fiat currencies), cryptocurrencies are decentralized and typically operate on a technology called blockchain. Each cryptocurrency transaction is recorded on a public ledger, ensuring transparency and security.
Cryptocurrencies can be used for various purposes, including online purchases, investment opportunities, and as a means of transferring value globally without the need for intermediaries like banks.
KYC Compliance: A Cornerstone of Global Crypto Regulatory FrameworksAny kyc Account
This presentation explores the pivotal role of KYC compliance in shaping and enforcing global regulations within the dynamic landscape of cryptocurrencies. Dive into the intricate connection between KYC practices and the evolving legal frameworks governing the crypto industry.
What Lessons Can New Investors Learn from Newman Leech’s Success?Newman Leech
Newman Leech's success in the real estate industry is based on key lessons and principles, offering practical advice for new investors and serving as a blueprint for building a successful career.
5 Compelling Reasons to Invest in Cryptocurrency NowDaniel
In recent years, cryptocurrencies have emerged as more than just a niche fascination; they have become a transformative force in global finance and technology. Initially propelled by the enigmatic Bitcoin, cryptocurrencies have evolved into a diverse ecosystem of digital assets with the potential to reshape how we perceive and interact with money.
Introduction to Metro in India by cosmo soil.pptxcosmo-soil
The metro system in India is a vital part of urban mobility, providing eco-friendly, efficient, and affordable transportation. This article explores its history, benefits, and future developments, highlighting how metros enhance quality of life and drive urban development.
Vadhavan Port Development _ What to Expect In and Beyond (1).pdfjohnson100mee
The Vadhavan Port Development is poised to be one of the most significant infrastructure projects in India's maritime history. This deep-sea port, located in Maharashtra, promises to transform the region's economic landscape, bolster India's trade capabilities, and generate a plethora of employment opportunities. In this blog, we will delve into the various facets of the Vadhavan Port Development: what to expect in and beyond its completion, and how it stands to influence the future of India's maritime and economic sectors.
CRYPTOCURRENCY REVOLUTIONIZING THE FINANCIAL LANDSCAPE AND SHAPING THE FUTURE...itsfaizankhan091
Cryptocurrency, a digital or virtual form of currency that uses cryptography for security, has revolutionized the financial landscape. Originating with Bitcoin's inception in 2009 by the pseudonymous Satoshi Nakamoto, cryptocurrencies have grown from niche curiosities to mainstream financial instruments, reshaping how we think about money, transactions, and the global economy.
The birth of Bitcoin marked the beginning of the cryptocurrency era. Unlike traditional currencies issued by governments and controlled by central banks, Bitcoin operates on a decentralized network using blockchain technology. This technology ensures transparency, security, and immutability of transactions, fundamentally challenging the centralized financial systems that have dominated for centuries.
Bitcoin was conceived as a peer-to-peer electronic cash system, aimed at providing an alternative to the traditional banking system plagued by inefficiencies, high fees, and lack of transparency. The underlying blockchain technology, a distributed ledger maintained by a network of nodes, ensures that every transaction is recorded and cannot be altered, thus providing a secure and transparent financial system.
June 20, 2024
CRYPTOCURRENCY: REVOLUTIONIZING THE FINANCIAL LANDSCAPE AND SHAPING THE FUTURE
Cryptocurrency: Revolutionizing the Financial Landscape and Shaping the Future
Cryptocurrency, a digital or virtual form of currency that uses cryptography for security, has revolutionized the financial landscape. Originating with Bitcoin's inception in 2009 by the pseudonymous Satoshi Nakamoto, cryptocurrencies have grown from niche curiosities to mainstream financial instruments, reshaping how we think about money, transactions, and the global economy.
#### The Genesis of Cryptocurrency
The birth of Bitcoin marked the beginning of the cryptocurrency era. Unlike traditional currencies issued by governments and controlled by central banks, Bitcoin operates on a decentralized network using blockchain technology. This technology ensures transparency, security, and immutability of transactions, fundamentally challenging the centralized financial systems that have dominated for centuries.
Bitcoin was conceived as a peer-to-peer electronic cash system, aimed at providing an alternative to the traditional banking system plagued by inefficiencies, high fees, and lack of transparency. The underlying blockchain technology, a distributed ledger maintained by a network of nodes, ensures that every transaction is recorded and cannot be altered, thus providing a secure and transparent financial system.
#### The Proliferation of Altcoins
Following Bitcoin's success, thousands of alternative cryptocurrencies, or altcoins, have emerged. Each of these altcoins aims to improve upon Bitcoin or serve specific purposes within the digital economy. Notable examples include Ethereum, which introduced smart contracts – self-executing contracts with the terms of the agreement
Learn From the Experts: Critical Elements of Effective Environmental Policies
1. LEARN FROM THE EXPERTS:
Critical Elements of Effective
Environmental Policies
Moderator:
Presenters:
Dianne P. Crocker, Principal Analyst, EDR Insight
Brian A. Ginter, VP & CCIM, Appraisal/Environmental Group,
Burke & Herbert Bank
Georgina Dannatt, VP, Environmental Risk Manager,
Bank of the West
Larry Schnapf, Attorney, Schnapf Law
3. The Evolution of Environmental
Due Diligence
2013
The OCC updates its
environmental policy for the first
time in18 years, expanding
scope of environmental
requirements—more in line with
FDIC guidance…
4.
5.
6. Best Practices in Lenders’
Environmental Policies
1. Work with qualified environmental professionals.
2. Define a tiered approach to due diligence.
3. Pre-screen all commercial property loans.
4. Require AAI-compliant Phase I ESAs, esp. high-risk loans.
5. Monitor property throughout loan term.
6. Document due diligence consistently.
7. Protect against liability in the event of foreclosure.
8. Train internal staff.
9. Track regulatory changes.
10. Conduct annual policy reviews, update as necessary.
7. Today’s Speakers:
Brian A. Ginter, VP & CCIM, Appraisal/Environmental Group,
Burke & Herbert Bank
Georgina Dannatt, VP, Environmental Risk Manager,
Bank of the West
Larry Schnapf, Attorney, Schnapf Law
8. Critical Elements of Effective
Environmental Policies
Webinar Event!
Tuesday, October 29, 2013
With scrutiny on lenders’ risk management policies
intensifying, more and more community banks are
writing their first policies or updating old ones.
One Manager’s
Perspective
9. Primary Purpose (Setting the Stage):
Comment on unique perspective in building policy from the Ground -Up
What are the critical components that should be in every policy?
What elements are common to most institution’s policies?
How does your institution measure up to industry best practices?
How is policy administered across organizations?
*Discuss your unique perspective in building policy from the ground up; developing and
maintaining. “Everything comes down to risk and value”.
*Observation: Regulatory focus has shifted with more attention on environmental risk
management, today, than ever before. Challenge – Environmental Risk Tolerance is
subjective and unique to each institution. Providing guidance and clarity for regulatory
acceptability is the challenge.
*What are you looking for from Environmental Professionals? (recommendations)
*How are you addressing concerns about regulatory scrutiny? What are examiners
looking for? What do you consider the primary trip-ups?
*I really, like the Comptroller’s Handbook – Commercial Real Estate Lending
(8/2013) 18-point checklist. Redrafting our current policy to address these points.
EDR Webinar
9
10. Four Simple Questions and Five Topic Points in 15
minutes – Right…
When first requested to participate in this discussion four main questions and five
bullet topics were provided as my discussion points…
No Challenge, how difficult could it be?
Realization: Yes I know… everyone out there just smiled. Once I realized my basic
points turned into 12 pages of outline I knew I had to focus my thoughts.
Let’s Get Started
EDR Webinar
10
11. Unique Perspective:
I joined Burke & Herbert Bank four years ago, as a 28-year veteran appraiser,
developer, and investor. That meant keep it applicable and simple.
Environmental challenges always come back to two points: Value and Risk
Taking this approach there are five primary points that any environmental risk
program needs to address:
1. Identify the Risk (education) – you must to know what the issues are before
you can understand the risk. This not only requires proper selection of third
party vendor / service providers, it also requires education for your internal
personnel; all personnel – Institution Size Subjective.
*Direct Staffing – providing interpretation and recommendations
*Loan Officers – ability to understand what is being communicated and
more importantly, they need to understand that the presence of an
environmental issue does not need to kill the deal.
*Operations – at least at our bank the force that pulls it all together.
*Senior & Board Level Management – Even more than the loan officers;
understanding that issues do not automatically mean denial.
2. Determine if or what the Cost to Cure Is - the issues specific to the property
and/or external influences? Is there a Cost to Cure? Can the issue be cured?
12. Unique Perspective:
3. What Is The Effect On Value - How is the effect going to be addressed?
Who is going to address it? Appraiser? Curtailment/Escrows? Environmental
Insurance? Mitigation/Clean-Up? Risk Level Underwriting?
4. Residual Risk? - Whether (2) above, is feasible or not, is there remaining or
residual risk associated with the property (remaining stigma, off site
issues, long-term clean up)?
5. What Is The Effect On Value - Back to (3). If there is residual risk, there is
a value concern. How are you going to address it?
Development of our risk management program started from these
points. It is these points that get to the hart of the risk and, in the
end, establish safe and sound risk management practice.
13. Policy Building Points:
Policy Building Points – in the beginning, and currently, I consider the most
relative and significant points to be:
The purpose of having a proper environmental risk management program is
not, simply, to satisfy regulatory compliance; the real goal of any
environmental risk program is KNOWING. Knowing what risks are present,
knowing who will address those risks, knowing how to mitigate those risks,
and finally, just knowing what needs to be done. Knowing is what will
protect the Bank and in the end the Customer.
From a Regulatory position, the focus is not just having a policy, it is also
having an implementation procedure in place; identifying responsible parties
throughout the process; oversight of the process; and being able to document
that process.
I can attest to, and believe many of the listeners today will agree, there
is increased attention on environmental risk management. What I found
lacking (typical) was a defined, clear, and concise structure or guide on
what is required and/or expected on the regulatory side. This is not a
criticism, but an observation. It is difficult to provide clarity on a topic
that is subjective by its very application – Tolerance Levels Vary.
Comes down to KNOWING & DOCUMENTING.
14. Policy Building Points:
Notwithstanding who our regulators are, I am currently reworking our
policy utilizing the updated OCC Handbook outline for, “…effective
environmental risk management program…”. This 18-point outline
identifies the questions and elements to be addressed in developing an
effective program. (Shown on later slides)
Note: your environmental risk management program must not only
address new mortgage lending, but must also address REO, OREO, and
have a system to monitor existing credits.
Note: Needed - A specific part of a proper risk management program is
a risk matrix. Typically, a risk matrix is segregated by property type
and loan amount. This matrix is risk-tolerance specific, by
institution, and will identify escalation points for increased
environmental due diligence.
15. Challenge:
Challenge: The question was posed; what are you looking for from EPs? Good
Question. I think I am speaking more to the smaller community bank sized
institutions when I say, typically, we do not have full environmental departments
or environmental engineers on staff. Many times, it’s just a sub-note to someone’s
job description; this is OK. With a properly written policy and access to vetted
third party service providers, there should be no difference in lending or
regulatory risk between those BIG BANKS and us.
Remember it comes down to KNOWING. Whether the initial due diligence
started with a simple questionnaire, a loan officer field inspection, or a full Phase I
& II with lead/radon/asbestos testing, vapor intrusion, and other studies it’s better
to know. If there is no one on staff with the expertise to determine the scope of
risk there are many service providers that can provide the expertise on a case by
case basis. I am not advising full studies on every credit; define your risk
tolerances and develop a Matrix.
Specifically, when I am requesting Phase I or II reports I want to know as much as
I can. This is not only specific RECs & VECs but, also any other observations, by
my expert (chemical storage, transformers, hydraulic systems, ect.), even if there
is no immediate risk. Additionally, I want commentary and recommendations
associated with any risks.
16. Challenge:
Challenge: The Risk Program must be written to EVERYONE…
•First and Foremost – Developed for the safe & sound operation of the
institution.
•Satisfaction of the Regulators
•Satisfaction of Senior Management & Board Members
•Satisfaction of the other supporting departments within the institution
•Last but not least – Satisfaction of the Lending Staff (they will never be
happy)
Challenge: Having a Risk Management Program that is comprehensive yet
provides the flexibility (with documentation) for exceptions. No two
situations are the same. Know & Document.
19. Exit Summary:
In Summary –
As with any Policy:
• Written
• Implementation Procedure
• Over-Site
• Documentation Process (document everything!)
Thoughts:
• any policy must be considered a living document - if and when new
information becomes available amend the policy.
• It is all about knowing; and when you know, document it.
Get a theme here… Know and Document!!!
That concludes my portion; I would like to turn this webinar over to Georgina
Dannatt with Bank of the West, who will clear up any confusion I may have
caused… . Q & A at the end of the program.
21. Why have an Environmental Risk Program?
With few perceived losses and protections of the Secured Credit
Exemption (1996 Asset Conservation Act), many banks moved credit risk
management focus away from environmental
• More appetite for risk as banks grew larger & more competition
for desirable properties
• Lenders moved risk thresholds up to adjust for increased
property valuations
But…
• Banks are required to have a environmental program
• Regulators increased the emphasis on risk management and
proactive procedures to minimize liability due to a perceived overconcentration of Commercial Real Estate risk
• Today’s properties can be inherently riskier- even “low risk” sites
may not really be low risk
• Market pressure for in-fill redevelopment, usually there was a
previous use
• Known contaminated sites and Brownfields
• Economic conditions may increase likelihood of foreclosure
22. Purpose of an Environmental
Risk Management Program
•
•
•
•
Satisfy Bank credit and sound lending practices
Satisfy regulatory requirements (Fed, OCC, FDIC, OTS, NCUA)
Understand and consider environmental concerns
Identify environmental conditions or liabilities which
could:
◦ Impact the borrower’s ability to repay the debt
◦ Impair Bank’s ability to recover funds in the event
of default
• Qualify for CERCLA liability protection (2002 Brownfield Amendments)
• Know what is in your portfolio / preplan exit strategy
23. Environmental Risks in Lending
• Impacts on Borrower
– Financial obligations for contamination cleanup, fines/penalties,
loss of permits could disrupt cash flow/ debt servicing
– Remedial action can result in access issues, business
interruption, installation of remedial systems or demolition,
health risks
– Deed Restrictions and Activity/Use Limitations may affect site
use, redevelopment, and construction plans
– Reduced collateral value- cost to cure contamination, stigma
– Construction delays
– Increased marketing time
– Inability to refinance
– Legal claims (3rd party lawsuits, OSHA, unions)
– Legacy risks (responsibility for past waste disposal/ releases)
24. Environmental Risks in Lending (cont.)
• Bank Foreclosure
– Bank may have to incur cost of investigation, decommissioning, waste
removal
– Unable to foreclose
– Must discount price in order to sell
– Indemnify purchaser
– Secured creditor exemption may say the bank does not have to do new
cleanup, but the reality is remedial work is often necessary in order to resell
– Bank not exempt from all environmental laws- Clean Water Act (esp.
stormwater), Clean Air Act, RCRA (chemical and haz waste
storage/disposal), OSHA, others
• Direct Bank liability can occur
– Participation in management of operations voids CERCLA exemption
– Need to fulfill Continuing Obligations- taking steps to properly contain or
stabilize release after foreclosure, or maintain ongoing cleanup activities
– In some states, must notify if contamination could pose an imminent risk
to public health
25. Lender Perspective
• The existence of past or present contamination does not
necessarily make a property unacceptable as collateral.
• Environmental risks must be fully understood and considered
in underwriting transactions- “eyes wide open”
• The fact that the borrower, their environmental
consultant, and/or an environmental oversight agency has
concluded a risk is acceptable doesn’t necessarily make it
acceptable to the lender.
• Bank reviews are done for the bank’s use only. Borrowers
and other lenders should not rely upon the results.
26. Environmental Policy
FDIC Requirements (FDIC Financial Institution Letter FIL-98-2006)
•
•
•
•
•
•
Establish an Environmental Risk Program
Designate a Senior Officer knowledgeable in environmental
matters to be responsible for the program implementation
Provide staff training
Require an environmental review or analysis during the
application process
Include loan documentation standards
Establish environmental risk safeguards in loan workout and
foreclosure situations.
OCC and other agencies have similar guidance. All guidance is
flexible so each bank can tailor to meet their situation.
27. Developing an Environmental Risk Policy
• Basic question is what kind of due diligence does the bank need?
• What is the purpose? And what will you do with the data?
• Banks design their own programs to fit their niche and risk
perspective
Considerations:
– Protect bank from issues during loan or upon foreclosure
– Bank’s appetite for risk – how much are you willing to lose?
(environmental risk is not related to the size of the loan)
– Front end assessment of risk vs. at back end when contemplating
foreclosure
– Competitive influences and regional/market factors
– In-house vs. Outsourced
– Recouping costs for due diligence
– Timing and hassle factors
– Bank regulator requirements/expectations
28. Developing an Environmental Risk Policy (cont’d)
• Support from Senior Management & willingness to enforce
• Identify transactions and collateral types subject to policy
• Develop a tiered due diligence matrix- less risky collateral and
lower value loans get less scrutiny; set de minimis levels
• Create screening approaches
• Define next steps for when an issue is identified
• Determine who has the authority to waive policy
• Educate bankers and credit staff
• Monitor portfolio
• Develop relationships with quality consultants and vendors
Goal: Identify environmental risks and factor into overall credit
analysis.
(Business and credit aspects may override environmental risks)
29. Create a Policy Matrix
Once the policy thresholds are set, create an easy to use
matrix
•
•
•
•
Reduces confusion by users
Defines collateral risk categories and loan threshold amounts
Conceptualizes bank’s financial risk tolerance stance
Be prepared for the matrix to flex
Typical Lender Environmental Due Diligence
• Environmental Questionnaire completed by borrower
• Tiered Due Diligence with screening level assessments for
smaller loans
Database, Desktop Review (=Database+Historicals), Site Visit, Transaction
Screen (TSA)
• Phase I Environmental Site Assessments for high risk properties
and for all loans at some selected Loan Amount
• Bank-ordered Phase I prior to any foreclosure, deed-in-lieu, or
other action to take ownership
30. Environmental Due Diligence Options
•Phase II (Performed by EP)
•Phase I ESA (Performed by EP)
•Transaction Screen Assessment (TSA) (Performed by EP)
•Desktop + Site Inspection (by Bank or EP)
•Desktop Review (Performed by Bank or EP)
•Database Report (Performed by Bank or EP)
•Environmental Questionnaire (completed by Borrower)
•Relationship Manager’s inquiry and/or Site Inspection
•None
More comprehensive as you move up
EP= Environmental Professional (consultant)
Many banks will choose to not to use all these assessment types
Phase II doesn’t supersede Phase I; the two serve different
purposes and are complimentary
31. Example Policy Matrix for Due
Diligence
-------------------------------- Loan Size -----------------------------------------------Collateral Risk
Type
<$500K
$500K - <
$1M
$1M - $2M
>$2M
New LoanLow Risk
Review EQ
EQ+Database
-orEQ+desktop
EQ+TSA
EQ+Phase I
New LoanHigh Risk
EQ+TSA -orPhase I
EQ+Phase I
EQ+Phase I
EQ+Phase I
New LoanLow or Med Risk
EQ+Review
Report
EQ+Rpt Rvw
+ either
Database
or Desktop
EQ+Rvw Rpt+
Desktop+Site
Inspect.
-orEQ+TSA
EQ+Ph I Update
-orEQ+new Phase I
RenewalLow Risk
Rvw EQ
EQ+Database
-orEQ+Desktop
EQ+Desktop or
EQ+Desktop+
Site Inspect.
EQ+Desktop+
Site Inspect.
-or- EQ+TSA
Renewal –
High Risk
EQ+Desktop
+
Site Inspect.
EQ+TSA
EQ+TSA for recent/
EQ+Ph I update for
older
EQ+Ph I update
-orEQ+new Phase I
Foreclosure
EQ+Phase I
EQ+Phase I
EQ+Phase I
EQ+Phase I
with Existing
Outdated Phase I
>12 mo. old
32. Typical Risk Ranking of Collateral
Low- office/hotel/multi-family/school/religious facility built after 1980 on
previously undeveloped land, raw land, crop land
Medium- older sites in urban areas, light industrial, small scale
chemical use, car wash, small auto repair, small medical/dental
labs, photographic lab, wineries, farms, agricultural product
packing, small above ground tanks
High- gas stations, underground tank sites, on-site dry cleaners
(chlorinated solvent use), plating shop, semiconductor/print circuit
board, older auto dealerships, large auto repair facilities, large-scale
chemical use, hazardous waste generator, junk yards, large car
wash, large trucking depot, landfill, tanneries, foundries, mining, large
dairies and feed lots, canneries, lumber treatment
Ranking applies to current, past, and future site uses.
List is not comprehensive. Each bank may define risks differently.
33.
ASTM E1527 & E1528
Develop a bank Scope of Work
Special requirements- SBA, Fannie Mae, Freddie Mac, HUD
Not all reports are equal
Reports should have a narrative and tell the property’s
story
Must answer questions and explain data gaps
Recognized Environmental Conditions (RECs) and
Business Environmental Risks (BERs)
The role of Agency File Reviews
Need to review from your bank's risk perspective
Approved consultants
34. Common Obstacles to Finance
•Information is not adequate to assess risks
•Project Feasibility – timing, accessibility
•Incomplete Assessment of Risks
•Unknowns
Mitigation of Environmental Risks
Correct environmental issues before closing
Correct after closing- holdback funds for cleanup (150%- 200%)
Reduce appraised value or loan amount
Include remediation costs in cash-flow
Underwrite as unsecured debt
Take additional collateral (due diligence will be needed for that property too)
Indemnification/ Funding commitments
Environmental Insurance
Combination of above
35. Making the World Safe
For Banks
Larry Schnapf
212-876-3189
Larry@schnapflaw.com
36. CERCLA Liability
Strict, Joint and Retroactive Liability
Four classes of Liable parties:
Past and Current Owners
Past and Current Operators
Defenses
Third Party Defense (requires due care)
Bona Fide Prospective Purchaser, Contiguous Property Owner, Innocent
Landowner
all appropriate inquiry
Post-acquisition “appropriate care”
Secured Creditor Exemption
Indicia of ownership without participating in management of facility
Foreclose but take commercially reasonable steps to sell property
37. Other Sources of Liability
Resource Conservation and Recovery Act
(RCRA)
State Superfund and UST Laws
(UST) Secured Creditor Exemption
Many have secured creditor exemption
State Superlien Laws
Common Law
Disclosure
38. Leading Sources of
Environmental Contamination
Historic dry cleaners
Historic gas stations
Historic manufactured gas plants
Historic wood treatment
Former bombing ranges
Vapor intrusion from off-site sources
39. Know Your Bank and Loan
Disposition
Traditional Mortgage Lender
Asset-Based Lender
Loan Syndication
Securitization
Refinance vs. New Loan
40. Typical Bank Concerns
Credit RiskBorrower Ability to Pay Loan
Value of Collateral
Direct Liability
Cleanup costs
Toxic Torts
Reputational Risk
42. Lender Environmental Risk
Management Program
Pre-Loan
ESA Scope of work
List of acceptable consultants
Identify transactions requiring Phase I ESAs
Reliance Language and Consultant Insurance
Review Process of ESAs
Commitment Letters
43. Risk Management Cont’d
When is Phase II required
Approval Process for Environmentally-Impaired
Loans
Escrows and Insurance
Communication With Borrower
Standard Loan Covenants and Indemnity
44. Risk Management Cont’d
Loan Administration
Periodic Monitoring
Permissible Oversight
Disclosure for Securitization and Syndications
Workouts and Foreclosure
Heightened risk
Reevaluate Environmental Issues
Review Federal and State Requirements
Security and Auctions
48. Other Risk Minimization Tools
Regulatory Approval
NFA, VCA or PPA
Extend to lender and successors
Confirms landowner defenses
Contribution Protection
Release of Lien
On-going Obligations
Serves basis for cost estimate
Know State Lender Liability Requirements
Remedial Action Plan (RAP)
Quantifies Cleanup Costs
Shows Site Fully Characterized
49. Risk Minimization Tools, cont.
Escrow or Holdback
Brownfield Programs
UST and Dry Cleaner Funds
eligibility
Covered costs (cleanup, PD,TP)
deductible
assignment of rights
Indemnity
Insurance
Guaranteed Remediation Programs
50. Elements of Indemnity
Address pre-existing known and unknown
contamination
On-Site and Off-site generator liability
Current and former owned or operated locations
Predecessors, former subsidiaries or business
units
Bodily Injury and Property Damage
52. Branch Office
White Swan Cleaner Superfund Site (BOA)
In the Matter of Hamburg Mills Creek Superfund Site,
Docket No. CERC-03-2013-004[
http://www.environmentallaw.net/2012/10/pa-bank-agrees-to-reimburseepa-for-removal-costs-at-owned-property ];
53. Auction/Sale Disclosure Cases
Rhima v JPMorgan Chase Bank, [
http://www.environmental-law.net/2012/06/banknot-liable-for-failing-to-disclose-environmental-issuesat-foreclosure-sale ]
Lusk v First Century Bank, [
http://www.environmental-law.net/2012/05/banknot-liable-for-auction-sale-of-contaminated-property ]
54. Auction/Sale Cases Disclosure
Cont’d
Ritschel v. Spencer Savings Bank, SLA, [
http://www.environmentallaw.net/2011/10/state-appeals-court-affirmsdamage-award-against-bank-for-sale-ofcontaminated-property ] [sale of former branch
office property]
In re Southbridge Savings Bank,
[(http://lschnapf.blogspot.com/2011_06_01_ar
chive.html ] [disclosure of oil tank spill]
55. Foreclosure on Contaminated
Property
Forest Park National Bank & Trust v Ditchfield, [
http://www.environmentallaw.net/2012/07/foreclosing-lender-rcra-action-mayproceed ]
Buckbee-Mears Co. Superfund Site, [
http://www.environmental-law.net/2012/09/bankenters-into-settlement-with-epa-for-contaminated-nysite
In matter of Rehrig-United International Site[http://www.environmental-law.net/2013/02/bankagrees-to-reimburse-epa-for-post-foreclosure-removalaction-costs/ ]
56. Foreclosure Cont’d
In the Matter of Ultimate Industries
Site, (f/k/a State of Ohio v Estate of Roberts] [
http://www.environmentallaw.net/2012/10/ohio-bank-to-partiallyreimburse-epa-for-removal-costs-related-todefunct-borrower-facility ]
In re Marble Cliffs Crossing[http://www.environmentallaw.net/2013/05/methane-gas-an-apartmentcomplex-and-a-bankruptcy-filing/
57. Trustee Properties
In the Matter of Browning Lumber[http://www.environmentallaw.net/2012/09/trustee-bank-agrees-toremoval-action-settlement-with-epa/]
58. Bank Subsidiary
Tennessee v. Roane Holdings Ltd., 2011 U.S.
Dist. LEXIS 143703 (E.D.TN 12/14/11) [
http://www.environmentallaw.net/2012/03/acquisitions-bring-cercla-liability-tobanking-conglomerate ]
Morgan Stanley Services Corp. v
NJDEP, 2011 N.J.Super. Unpub. LEXIS 182 (App.
Div. 1/26/11)[
http://lschnapf.blogspot.com/2011/02/courtreverses-revocation-of-nfa-letter.html ]
59. Miscellaneous
Alfieri v. Bertorelli, 2011 Mich. App. LEXIS 1796 (Mich.Ct.
App. 10/18/11)[ http://www.environmentallaw.net/2011/11/state-court-reduces-damages-of-condopurchaser-because-it-failed-to-conduct-environmentalinvestigation/ ] [condo financing]
Casale v Segal & Morel, 2011 N.J. Super. Unpub. LEXIS
1228 (App. Div. 5/12/11) [defective radon system]
Ridge Seneca Plaza v BP Products, et al, 2011
U.S. Dist. LEXIS 47288 (W.D.N.Y. 5/2/11) [
http://www.environmental-law.net/2011/10/ny-case-illustrateswhy-borrowers-should-not-simply-rely-on-lender-approval-ofphase-1 ][reliance on prior phase 1]