Professional Documents
Culture Documents
Procedure No.
200-14
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Subject:
Procedure No.
200-14
TABLE OF CONTENTS
Page Number
1.
Scope
1.1
Applicability
1.2
Effective Date
2.
3.
Process Steps
3.1
Requirements
3-12
3.1.a
New Dealers
3-9
3.1.b
3.1.c
On-going Dealer
3.1.d
3.2
OI Product Reviews
11-13
3.3
13-14
3.4
System of Record
9-10
10-11
11
14
4.
14
5.
Governance
14
5.1
5.2
Exceptions
6.
Revision History
7.
Appendices
15
15-18
16
17
18
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Subject:
Procedure No.
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1.
Scope
1.1
Applicability
excluding Wholesale.
Effective Date
Process Steps
3.1
Requirements
3.1.a
New Dealers
All new Dealers applying to do business through an approved program must go through an initial review
process conducted by the Channel Management team. This is referred to as a Dealer onboard
screening.
The following attributes are evaluated during the screening:
Corporate Standing status of an organization with respect to being current on statutory dues
and the filing of required reports within a state
Address & Site Verification validation of the dealers address to ensure it is an accurate
reporting of the dealers location, and that the location is non-residential and appears equipped
to conduct sales in their industry. Acceptable sources for Address Verification are Lexis Nexis,
Google, or Google Maps search by address. Acceptable sources for Site Verification are Google
Maps Aerial View, and
Employee visit.
Standard industrial classification (SIC) Code a numerical code that indicates an organizations
industry segment affiliation within the economy
AML/Compliance Screening: a review using the Bridger Enterprise (Bridger) system to check for
Irregular Business Practice (IBP), Adverse Media, Office of Foreign Asset Control (OFAC) and
Watchlist, where applicable. Please refer to:
AML/KYC Policy for further guidance.
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Subject:
Procedure No.
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The below, Dealer Onboarding/Reactivation Criteria Matrix (Matrix A), provides guidance on
screening decisions for a variety of Dealer programs.
OI
Diversified
Programs
(Formerly CS)
APPLE
OTHER IT
DOOSAN/
BOBCAT
NACCO
OR Score
16
13*
15
15
Per Whol es a l e
Deci s i on
16
TENURE
1 Yr
2/4 Yrs
3 Yrs
2 Yrs
Per Whol es a l e
Deci s i on
2 Yrs
Requi red
1) Requi red for > $1MM
LVO
2) Requi red for a ny a dd'l
product a pprova l s
Requi red
Requi red
N/A
Per Whol es a l e
Deci s i on
Requi red
N/A
N/A
N/A
Requi red
Requi red
OEM AUTHORIZATION
NEW VENDOR
AGREEMENT
DOCUMENTATION
* OR14 & OR15 can be approved if beneficial owners are identified and are clear on Bridger and adverse media searches
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Procedure No.
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OR Score
Si te Vi s i t
Excepti on ca n be ma de i f dea l er i s
regi s tered i n one s ta te w/condi ti on tha t
wi thi n 60 da ys they regi s ter i n s ta te they
a re doi ng bus i nes s .
Ma y a pprove ba s ed on:
1) Uti l i ty bi l l (other tha n phone)
2) Ma nta
3) Dea l er webs i te(i f onl y for a new bra nch
of a n otherwi s e previ ous l y es ta bl i s hed
dea l er)
4) New fa ci l i ty l ea s e a greement
5)
empl oyee vi s i t
No a uthori ty to wa i ve requi rement
Tenure
Addres s Veri fi ca ti on
SIC Code (Stri ke Zone) Proper SIC code No a uthori ty to wa i ve requi rement
for progra m
AML/Compl i a nce Screeni ng See Page 7 No a uthori ty to wa i ve requi rement
& 8 Process Steps for AML/Compliance
Screening
Examples include:
Strategic Alliance Agreement (SAA),
Resellers Agreement, Dealer Reserve
agreement, etc
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Procedure No.
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Description
OI
Diversified
Programs
(Formerly CS)
APPLE &
OTHER IT
NACCO
X
X
5200 Building Materials, Hardware, Garden Supply, And Mobile Home Dealers
X
X
X
X
The sales team creates a Partner record in SalesForce and creates a Siebel Activity.
and CM Analysts)
2.
In addition to the items in #1 above, an auto-Submittal is sent to Siebel with Dealer Review
Submittal Type and entered into the Siebel Touchless Flow process, where the Dealer is entered
as a customer. A Submittal number is generated with the results of the credit review which
includes an OR rating, SIC code, Adverse Media and KYC/IBP screening results.
verifies
legal name, corporate standing and tenure using the individual SOS (secretary of state) websites.
Info from this verification is entered as a record in Siebel. Results of the Adverse Media check,
along with Dealer owner name check in Bridger (if applicable), are entered in Siebel. A Paynet
Report is also pulled.
3.
assigns the Activity to the CM Analyst queue. The CM Analyst performs additional
review confirmations including Paynet Report, address, OEM and site visit verifications. The CM
Analyst will then decision the Dealer using the program guidelines. Siebel is updated to show
the decision and the Activity is assigned back to the CM Analyst queue.
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Procedure No.
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updates the Activity Comments with the decision, and proceeds with creating the
VVLOC.
4.
5.
The VVLOC is created in Siebel and this information is fed to both Cheetah and SalesForce with
the below classifications.
If declined, the activity is marked DONE and the Dealer is in REJ (rejected) status. The
sales team is notified that the Activity is done and the Dealer is unapproved. They
may appeal the decision - See step 7 below. If not, this ends the Dealer onboarding
process for rejected Dealer.
If approved but program requires an SAA, the activity is marked DONE but the Dealer
is in PND (pending) status. The sales team is notified and the Dealer is pending until
executed SAA is returned and approved.
If approved but program does NOT require an SAA, the activity is marked DONE and
the VVLOC is placed in appropriate approval status. The sales team is notified that the
activity is done and the Dealer is approved to start submitting deals. This ends the
Dealer onboarding process for approved Dealer.
b.
c.
Upon execution of the SAA by the dealer, the sales team will create another
Activity for the executed SAA.
d.
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The sales team will, at their discretion, create another Activity thru SalesForce to
initiate the SAA document creation.
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e.
6.
b.
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The sales team may request a decision appeal by creating a new activity.
o
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3.1.b
1.
AML/KYC Policy
a. If the Dealer is decisioned by the system as a Bridger PASS, this is documented in the Siebel
record and the Dealer continues through the remainder of the onboarding approval process.
b. If the Dealer is decisioned by the system with a Bridger FAIL an auto-Activity is opened to
the AML
COE.
If the AML
COE team deems the hit to be a FALSE POSITIVE, the AML Activity &
CM Submittal are noted and the AML Activity is closed. The Dealer then continues
through the remainder of the onboarding review process.
If the AM
COE team deems the hit to be a TRUE HIT or if they are not able to
make the decision for FALSE POSITIVE based on the info provided, the AML Activity is
assigned to the AML Screening COE Flow team for further review.
2.
3.
The
AML Compliance team will do additional research and make a final decision on the status
of the Bridger hit.
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a. IF the AML team deems the hit to be a FALSE POSITIVE, the AML Activity & CM Submittal
are noted and the AML activity is closed. The Dealer then continues through the remainder
of the onboarding review process.
b. If the AML team deems the hit to be a TRUE HIT, they may give further direction of Do
Not Proceed based on the info provided, existing Compliance issues related to the hit, or
further discussion with the Risk Leader for the related program. The AML Activity and CM
Submittal are noted with TRUE HIT and further direction of Do Not Proceed, then the AML
Activity is closed. The CM Analyst will reject the CM Activity and CM Submittal. This ends the
onboarding process for rejected Dealer.
c. If the AML team deems the hit to be a TRUE HIT with further direction of OK to Proceed,
the business is allowed to proceed at their discretion, however the CM Analyst will reject or
approve the CM Activity and CM Submittal based on discussion with the CM Leader.
4.
If approved, the Dealer then continues through the remainder of the onboarding
review process.
There are times when moving forward with onboarding is acceptable for a system TRUE HIT. For
example, a
Dealer review that detects a required IRS 8300 form (Report of Cash Payments over
$10,000 Received in a Trade or Business) has not been completed would be raised as a potential IBP.
However, this IRS reporting issue would not necessarily prohibit transacting business with that Dealer in
3.1.c
On-going Dealer
On-going Dealer reviews are conducted based on the following requested situations:
Dealer Reactivation: A previously active Dealer has been inactivated and is requesting
reactivation. A full review will be conducted by the CM team. See 3.1 (above) for new Dealer
screening guidance.
Additional VVLOC for new Dealer Location: An active Dealer desires a new VVLOC to be
established for a new location. An address verification of the new location will need to be
performed by the CM team.
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Procedure No.
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3.1.d
If the Dealer has been active and not subject to a full review for more than 24
months, the CM team will conduct a full review. See 3.1 (above) for new Dealer
screening guidance.
If the Dealer has been active and reviewed within the last 24 months, the CM
team will conduct an OEM authorization check of the new program only.
The process steps for onboarding a new Payee replicate the steps for onboarding a new Dealer with the
exception of the site visit, OR Score & SIC Code consideration, and tenure, which are not required.
3.2
OI Product Reviews
OI Product reviews An OI Dealer may request to participate in various product offerings. Upon request,
in addition to the onboarding criteria listed above, the Dealer may be evaluated based on the following
criteria for participation in the product program:
Sales volume dollar amount of annual sales revenue generated by the Dealer
Financial Statements income and balance sheet statements provided by the Dealer
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The below, OI Product Review Criteria Matrix (Matrix D), provides guidance on screening decisions
for a variety of OI Products.
PRODUCT UNDERWRITING GUIDELINES
PROGRAM LEVEL
Transaction Level
Private Label w/
Dealer Return of
Immediate
Points in Rate
Standard Private Waive Phone Equipment
Notification
(6-10)**
Label
Audit (WPA)* (ROE)*
FOF
CPC
1 year
2 years
2 years
2 years
5 years
2 years
2 years
1 year
1 year
$1MM
$5MM
Criteria
Tenure in Business
Tenure with GE
Sales Volume
OR Score
2 Years Fiscal Year End Financials (and interim)
No Material Derogs
No Prior History of Problems w/ GE
SAA Required
Individual Deal Size
Dealer Status
QLIKVIEW CRITERIA
90+ Day Delinquency
LTD/Loss to OEC
16
16
16
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
13
No
Yes
Yes
Yes
13
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
<$75M
AP-T or APP
<$75M
AP-T or APP
NOTES
** POINTS IN RATE (1-5): Do not require approval. A credit Review and Qlikview Summary info will be sent to the Program Risk Manager (PRM) for decision on
Points in Rate (10+).
* WPA & ROE: For transactions >/= $75M, Credit Review & QLIKVIEW Summary info will be sent to the PRM for decision.
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Procedure No.
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The OI Product Review Exceptions Matrix (Matrix E) further outlines acceptance criteria and
approval authority levels for dealer product approvals:
Attributes
History/Portfolio Performance
Transactional request not included in
executed SAA
3.3
CM receives a request to update bank information, and is provided a completed and signed
Recurring ACH-Wire Bank Info Form or other acceptable documentation (see Appendix 2).
CM confirms completeness of form and authorization of signer on Bank Info form (see Appendix 3)
CM contacts the bank to confirm the Dealer is owner of account provided, the account # is correct
and ABA Routing # provided is correct for payment method requested (ACH or Wire). If a copy of a
voided check was provided, it can be used for account name & account # verification, but the
Routing # must still be verified.
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If the bank requires authorization from customer to confirm bank info, CM will fax or
email the Recurring ACH-Wire Bank Info Form to bank. A follow-up call will be made to
make confirmation or arrangements made for return fax or email.
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If the bank cannot make confirmation with 3rd party under any of the circumstances
described above, CM will advise Sales. Sales will contact the Dealer to request them to
contact their bank for an exception.
CM inputs the verified bank info in Siebel, which will feed to Cheetah.
CM notifies the Treasury Operations team of the bank info update, when Wire information has
been added to the system, providing the required screen shot for their record.
3.4
System of Record
The CM team uses a variety of programs while conducting the reviews described above, including
Siebel, Lexis Nexis, Secretary of State (SOS) websites, etc. However, the system of record for verified
Dealer data is Cheetah.
4.
5.
Senior Risk Executive (SRE) is (Owner) and is responsible for ensuring that Risk
Classifications are being assigned according to
requirements.
Operating Risk Leader maintains this SOP and ensures the current version is properly
documented and retained. The Operating Risk Leader also interprets and communicates
updates to the appropriate Risk personnel.
Policy Governance
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SRE
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Procedure No.
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6.
Version
1.0
2.0
7.
Revision History
Approval Date
06/16/2014
06/22/2015
Original
Refreshed to new Procedure format. Added sections 3.1.a. & 3.3
Appendices
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Procedure No.
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Appendix 1
Key Terms & Definitions
Cost Per Copy (CPC) OI product that allows for bundling of service & equipment payment, and
may include charges for per copy usage. This is also referred to as Usage Based Billing (UBB).
Dealer Company that sells retail equipment to
to lease or loan to end users. In regard to this
SOP, the terms /Dealer/partner/resellers are used interchangeably.
Fund Off Fax (FOF) OI product whereby
remits funds to a Dealer with electronic copies of the
lease contract being deemed acceptable documentation.
Payee any person or entity receiving proceeds from the Portfolio Management System (PMS)
receivable module.
Points in Rate OI product that allows Dealers to add additional points to the standard rate card rate,
when calculating the rate charged to the customer.
Standard Private Label OI product where the Dealer is Lessor on the lease and billing and
collection is in the name of the Dealer (without reference to
Private Label with Immediate Notification an OI product where the Dealer is Lessor on the
lease, but
notifies the customer immediately of assignment, with billing and collection in GEs
name.
Strike Zone A targeted group of SIC codes in which a program are expected to operate. An
approved Dealer should be affiliated with a SIC code that falls within the Strike Zone of their
program. See Matrix C for Strike Zones by program.
VVLOC (Dealer/Dealer LOCation) a two part code representing the Dealer Record. A dealer can
have multiple Dealer LOCations under one Dealer as each is a separate location (address). The first
part of the code Dealer Code - (up to 6 characters) represents the Dealer Program within the
Cheetah/PMS hierarchy. The second part of the code Dealer LOCation (up to 6 characters)
represents the dealer branch locations. For example, the vvloc for Joes Equipment Inc in Wichita,
KS is
123456.
123456 signifies the branch location for the dealer.
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Appendix 2
Bank Verification Options Grid
Dealers/Payees
Completed Bank Info Form signed by Authorized
Signer (see bank info form)*
Copy of Voided Check / Pre-printed Deposit Slip
with completed Bank Info Form
Bank Info Loaded on Existing Payee Code
Confirmed Match for Wholesale Setup
Verification of Routing # will be needed for all options requiring a Bank Info Form
* Verbal or written confirmation will be made with the bank
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Appendix 3
Bank Info Form Authorized Signer Requirements Grid
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