Presented by: Service Banking Officers

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Presented byService Banking Officers
Banking Liaison Officer Training Session
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Agenda

• Introductions
• Overview
• History of Banks and Credit Unions
• Banking Liaison Officer (BLO) Resources
• Installation Roles and Responsibilities
• Domestic Financial Institution (FI) Establishment
• Domestic FI Solicitation
• FI Termination
• ATM Solicitation
• Treasury General Account (TGA)
• Operating Agreements
• Morale, Welfare, and Recreation Sponsorships
• Leases
• In-Kind Consideration
• Financial Education
• Overseas

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Services Banking Liaison Officers (BLOs)
Army Banking Liaison
Officer [phone]
Air
Force Banking Liaison Officer (301)
981-7785 Banking Liaison Manager (301)
981-7767 Navy Banking Liaison Officer (202)
685-6738 Banking Liaison Manager (202)
685-6752 Marines Banking Liaison Officer
[phone]
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DoD Financial Institution Overview
Office of the Under Secretary of Defense
(Comptroller) (OUSD(C)) Provide policy guidance
Military Service BLOs/CULOs
DoD Banking and Credit Union Office Columbus, Ohio
Installation BLOs/CULOs
Installation FIs
Overseas Credit Unions
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History of DoD Banks and Credit Unions

• Banks
• Country began mobilizing in 1941
• Disbursing officers needed cash for payrolls
• First stateside military banking facility
  commenced in 1942
• at Ft. Sill, Oklahoma
• Overseas military banking facilities commenced
  in 1947
• Credit Unions
• The first state credit union act passed in 1909
• Owned and controlled by its members
• Serve groups that share something in common
• Credit unions are not for profit
• Serving and supporting DoD since 1928
• First overseas defense credit union opened in
• December 1967

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History of Overseas Banking and Credit Union
Programs

• Transferred to DFAS from OUSD(C) DoD Reform
  Initiative Directive 7
• 1 January 1998 Overseas Military Banking
  Program (OMBP)
• OUSD(C) transferred responsibility for the
  oversight, control, and management of the
  day-to-day operations to DFAS
• 13 July 1998 Domestic Bank Credit Union
  Programs
• OUSD(C) transferred responsibility for the
  programs and procedures governing banks and
  credit union on DoD Installations.
• OUSD(C) retained policy oversight for DoDI
  1000.11
• September 2000 Volume 5, Chapter 34,
  Procedures Governing Banks, Credit Unions and
  Other Financial Institutions on DoD Installations

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Banking Liaison Officer (BLO) Resources

• Banking Liaison Officer Policy, Procedures, and
  Desk Guide
• DOD Instruction 1000.11 Financial Institutions
  on DoD Installations
• DoD FMR, Volume 5, Chapter 34 Procedures
  Governing Banks, Credit Unions and other
  Financial Institutions on DoD Installations
• http//www.defenselink.mil/comptroller/fmr/05/05_3
  4.pdf
• Commander Installation Banking and Credit Union
  Liaison Officer Desk Guide
• http//www.dfas.mil/more/referencelibrary/bankingl
  iaisonofficerguide.html
• DoD Instruction 1344.07 - Personal Commercial
  Solicitation on DoD Installations
• DoD Instruction 1342.27 - Personal Financial
  Management for Service Members

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Examples and/or Questions

• Question What information does the BLO Guide
  provide that the DODFMR
• Volume 5, Chapter, 34 or DoDI
  1000.11 does not?

• Answer
• Morale, Welfare, Recreation Event Sponsorship
  Challenges
• Sample Banking Liaison Officer/Credit Union
  Liaison Office Appointment
• Information on In-Kind Consideration
• Information to establish or change a TGA
• Various policy memorandums from OUSD(C)
• DoD Designated Foreign Geographic Franchise
  Assignment Listing
• Information about the Overseas Military Banking
  Program Contract

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Installation Roles and Responsibilities

• BLO
• Vital link between the Commander and the FI, and
  assists in resolving complaints
• Monitors on-base financial services
• Keeps FIs informed of pending developments
  impacting services e.g., deployments
• Ensures lease and operating agreements are
  current
• Works with Personal Financial Managers to educate
  them on the financial educational resources
  provided by the on-base FIs
• Installation Commander
• Assign BLO
• Ensure suitable financial services
• One bank/credit union per installation must seek
  financial services from only on-base
  FIs
• Provide office space and logistical support IAW
  regulations
• Invite FIs to participate in newcomer briefings
  and financial education seminars
• Financial Institution Manager
• Comply with applicable laws, regulations,
  policies, and procedures
• Maintain liaison with Installation Commander,
  base leadership, and BLO
• Ensure adequate staffing
• Coordinate leasing/operating agreements with BLO

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Domestic Financial Institution (FI) Establishment

• Establishment
• Installation Commanders will request banking
  services IAW regulation.
• DoD FMR, Volume 5, Chapter 34
• paragraphs 340502 and 340702
• DoD Instruction 1000.11
• Services will review, solicit for, and approve
  banking needs as necessary.
• Requests for the establishment shall include
  all information listed in
• paragraph 340502A
• Number of DoD personnel who are eligible to use
  the FI services
• Distance and transportation to financial
  institutions in the vicinity
• Number of DoD personnel confined to the
  installation
• Name and location of the TGA depository
• List of organization and nonappropriated fund
  accounts
• Description and photographs of proposed space

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Examples and/or Questions

• Situation The need to establish a financial
  institution aboard a DoD installation
  following the departure of the current on-base
  financial institution.

• Resolution
• The Installation Commanding Officer (ICO)
  notified the Deputy Assistant Secretary (DAS).
• The ICO highlighted a need for financial services
  on the installation. Subsequently, the ICO
  endorsed and forwarded a request for financial
  services to be provided by an outside financial
  institution to the DAS.
• DAS reviewed the request and granted permission
  to solicit.

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Domestic Financial Institution Solicitations

• Solicitations
• Solicitation performed IAW with DoDFMR, Volume
  5, Chapter 34,
• paragraph 340503
• Scope dependent on service (designee) or
  installation commander
• Solicitation letters sent to local financial
  institutions and published in the local
  newspapers
• If necessary, solicitations can be expanded to
  a larger geographic area and published on
  Federal Business Opportunities (FedBizOpps) and
  trade journals.
• Military departments work closely with
  Association of Military Banks of America and the
  Defense Credit Union Council to obtain additional
  services.
• Operating agreement and lease signed prior to
  operating on the
• installation

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Examples and/or Questions

• Situation Establishment of a financial
  institution aboard a DoD installation
  following departure of current on-base credit
  union

Question What is the normal protocol for
conducting a solicitation?

• Resolution
• Solicitation announcement was released by the
  installation.
• Upon completion of the solicitation, ICO drafted
  an endorsement of recommendation and forwarded it
  to the DAS for approval.
• DAS reviewed and provided concurrence. Upon
  concurrence, installation and FI were required to
  enter into an operating agreement before
  operations could commence.

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Terminations

• May occur due to mission change, performance,
  merger, or violations
• FIs are required to provide 180 days advance
  notice of intent to close

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Examples and/or Questions

• Situation The ICO learned that the current
  on-base financial institution wishes to
• terminate its operations
  on-base.

• Questions
• Can the installation allow the lease to expire
  under its own terms and bring on another credit
  union? What are the terms for termination?
• What recourse does the Command have?

• Resolution
• To grant approval, ICO and/or the Banking Liaison
  Officer must have received written notice from
  the departing FI 180 days in advance to
  advise/assist the ICO in determining
• AND
• Ensure the departing FI has met all other
  requirements for termination within DoDFMR Volume
  5, Chapter 34, Paragraph 340703.

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ATM Solicitation Process

• On-base FIs have right to first refusal.
• Solicitation process required if on-base FIs
  decline to perform service or if there are no FIs
  on the installation.
• Exception to policy required by Service Secretary
  to conduct solicitation for ATM service when FIs
  are on installation.
• Commander conducts solicitation and forwards
  recommendation to the Service Secretary for final
  approval.

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Examples and/or Questions

• Situation Base wanted to bring ATMs on post to
  support special events
• Base had a temporary ATM requirement to have
  portable ATMs at an event
• Base BLO contacted on-base FIs with requirement

• Outcome
• FIs declined to provide ATM service but were not
  opposed to an off-base FI providing the service
• Base requests temporary waiver to the one
  bank/one credit union rule to solicit an off-base
  FI to provide ATMs at the event
• Temporary approval was granted for the event
  only. Any future use of off-base FIs requires
  a separate approval

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Operating Agreement

• An operating agreement is
• A document that defines the relationship
  between the FI and installation
• FIs must have current operating agreement prior
  to commencing operations.
• Negotiated between the installation commander
  and the FI and reviewed every
• 5 years
• A copy of the operating agreement should be
  sent to your respective military
• department BLO.
• An operating agreement should include the hours
  of operation, agreement to
• comply with DoD policies and procedures,
  security requirements for cash
• shipments, and an agreement to reimburse the
  government for logistical
• support.
• Any changes to the operating agreement must be
  approved by the installation
• commander.

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TGA

• Commercial banks or other FIs which have been
  designated specifically and authorized by the
  Department of the Treasury to maintain a demand
  account in the name of the Department of the
  Treasury for the purpose of accepting deposits to
  the TGA from disbursing officers.
• These depositaries are designated only at
  locations where they are needed to receive
  deposits of public funds for credit to the TGA.
• An Agency Profile Sheet is submitted to formally
  request authorization to deposit funds with a TGA
  or to change from one authorized depositary to
  another.

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Examples and/or Questions

• Situation The FI on base wants to stop
  providing TGA service. What recourse
• does the Command have?

• The FI notified the treasury and base they would
  be closing their TGA.
• The TGA was a requirement in the operating
  agreement.
• As a result, the base had to decide to use an
  off-base TGA or terminate the operating agreement
  with the current FI and solicit for a new FI to
  come on base that would have a TGA.
• Using an off-base TGA would have caused
  additional time and security costs to the base
  organizations.

• Resolution
• The FI reconsidered their decision and continued
  to operate the TGA

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Morale, Welfare, and Recreation Sponsorship

• Sponsorship must be consistent with other DoD
  and military department
• policies (DoD Instruction 1344.07, Personal
  Commercial Solicitation on DoD
• Installations).
• Sometimes a challenge misunderstanding and
  unfamiliarity with regulatory
• guidance
• Cannot be used to gain access to collect
  information for solicitation
• Cannot advertise and distribute competitive
  financial services/products
• literature

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Examples and/or Questions

• Situation Material distributed by off-base FI
  sponsoring MWR events
• Base BLO requested guidance on what information
  could be distributed by off-base FI sponsoring
  events

• Questions
• Is the 2002 OUSD(C) memorandum on sponsorship
  still valid?
• What is the purpose of an operating agreement?
• How often must the operating agreement be
  updated?
• What prevents off-base FIs from distributing
  competitive information?
• Why are on-base FIs granted exclusivity?

• Resolution
• Off-base FIs cannot distribute competitive
  literature for services listed in the operating
  agreement.
• Distribution of materials must also comply with
  DoDI 1344.07.

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Examples and/or Questions

• Situation Financial materials distributed by
  MWR sponsor at on-base event

• Base BLO should work with the on-base FI during,
  at, and before all events where outside FI
  sponsorship is planned.

• Questions
• Who reviews the DoDI 1344.07 to ensure products
  presented do not compete with the on-base FI?
• Who do I coordinate with to correct these issues?

• Resolution
• BLO reviewed materials to ensure compliance
• Discussed the event with the FIs on base to
  ensure they did not have any issues with the
  materials being presented
• Requested to review the MWR sponsorship agreement
  to ensure limitations and exclusions were
  explained to the FI or vendor

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Examples and/or Questions

• Situation Mobile ATM needed for MWR event MWR
  contracted service with off-base FI

• Base BLO should clearly review the installation
  request for services

• Questions
• How much time does the FI have to respond to a
  request for service?
• If initially they can not support the request, is
  my job complete?
• When do I get the service BLO involved?

• Resolution
• Once the on-base FI could not fit the request,
  the local BLO contacted the Service BLO for
  exception to policy (MWR already had contract).
• Base FI Identified they were not given sufficient
  time to respond to the request
• Reviewed the request completely and noticed the
  request could be filled by the on-base FI and all
  parties were in agreement
• Prevented the violation and on-base FI supported
  the event successfully

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Leases

• Leases allow the FI to provide service on the
  installation
• On-base FI must enter a lease prior to
  commencing operations.
• Terms shall not exceed 5 years except where the
  FI uses its own funds to improve existing
  government facilities (up to 25 years for
  construction).
• Consideration for lease will be based upon fair
  market value (FMV) exclusive
• of any improvements made.
• Credit unions shall be offered no cost leases
  in government facilities if they meet the 95
  percent criterion.
• Government has right to terminate lease
• Lease can be paid by cash or in-kind.
• In-kind consideration (IKC) IAW Title 10,
  U.S.C., Section 2667
• Military departments differ in their procedures
  and types of consideration.

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In-Kind Consideration

• Military departments met with the Army Corps of
  Engineers and Naval Facilities
• Engineering Command to develop standards for
  IKC.
• Leases are based on FMV appraisal.
• IKC includes other services such as
  financial services provided by
• on-base FIs.
• IKC process generally takes about 1 year and
  therefore must begin early
• with the involvement of the BLO.

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Examples and/or Questions

• Situation The lease between the FI and the
  installation is a process
• The BLO should understand the specifics of the
  lease and ensure it is updated, current, and
  valid.

• Questions
• What does the lease cover?
• Are leases between the installation and all FIs
  the same?
• Does the Staff Judge Advocate (SJA) review the
  lease?

• Resolution
• The lease details all the space to occupy,
  logistical support provided by the installation,
  responsibility of the FI, and percent of IKC as a
  discount.
• Provided information to base personnel on cost
  versus no cost leases
• SJA did review some leases to ensure all areas
  are addressed and both parties are covered they
  issued a legal opinion.

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Examples and/or Questions

• Situation In Kind Consideration negotiation
  process
• Base BLO should work with the on-base FI and
  installation support to ensure this process is
  completed timely, accurately, and fairly.

• Questions
• What does the FI do to start the process?
• Who assesses value to the services provided and
  adjusts the lease cost?
• Are all services provided grounds for IKC?

• Resolution
• The FI submits a list of services provided and
  the savings to the installation.
• The U.S. Army Corps of Engineers and G8 determine
  what discount value, as a percentage of the total
  lease, is assigned.
• Some services the FI lists and assigns a value
  may not be deemed as IKC but more of a marketing
  service resulting in a 0 percent discount or more
  information may be required.

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Financial Education

• On-base FIs provide no cost financial education
  training and counseling.
• Preference to conduct personal financial
  instruction should be extended to
• on-base FIs.
• Nongovernment/noncommercial organizations may
  be used for financial
• education.
• Must be approved by Presidential-appointed,
  Senate-confirmed DoD
• official
• Materials must be approved by commander and
  include disclaimer.
• DoD Financial Readiness
• Goal is to improve financial readiness
• DoD Instruction 1342.27, Personal Financial
  Management of Service
• for Service Members, Nov 12, 2004
• Build wealth and not debt

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Examples and/or Questions

• Situation Financial education training
  conducted by off-base organizations
• The on-base FIs have the right of first refusal.

• Questions
• Can off-base entities be contracted or requested
  to provide education?
• Are the FIs allowed to promote their specific
  products and services during financial education?
• Can other on-base organizations request the FI to
  provide education?

• Resolution
• Leadership issued a directive to organizations to
  utilize the on-base FIs to provide financial
  education.
• Educated the installation organizations on the
  role of the on-base FIs, the BLO, and the support
  they provide to the base and other financial
  education partners
• Coordination with the FIs should be through the
  BLO.

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Overseas Military Banking Program Contract and
Customers

• Community Bank DoD owned
• Operated by Bank of America
• Contractor management fee paid by Military
  Departments
• Operating expenses funded through earnings
• Products, services, and charges set by service
  level BLOs/OMBP
• Military personnel and dependents
• DoD civilian personnel and dependents
• Military disbursing officers
• Defense credit unions
• Organizational clients

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Overseas Financial Institutions

• General Information
• Community Bank operates under the DoD contract
  which includes hours of operation, services to be
  provided, and operating locations.
• Credit unions operate with an approved geographic
  franchise.
• Established when a demonstrated and justified
  need exists and DoD has the appropriate approvals
  to operate in a given country
• Country approval includes permission to operate
  under the status of forces agreement and/or other
  intergovernmental agreements, a diplomatic note,
  and host country banking industry approval.
• Provided no cost logistical support to the
  maximum extent possible

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Overseas Financial Institutions (cont)

• Establishment
• Installation or community commanders requiring a
  financial institution or ATM must submit request
  through command channels to the secretary of the
  military department concerned (or designee) for
  concurrence and transmittal to the Director of
  DFAS for approval.
• Request shall include, but not limited to
  approximate number of authorized personnel,
  distance to nearest financial institution or ATM,
  availability of official and public
  transportation, etc.

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Overseas Financial Institutions (cont)

• Geographic franchise information for credit
  unions
• A Geographic Franchise is the authorization
  granted to a credit union by the OUSD(C) to
  provide financial services in a specific
  geographic region located outside the United
  States, its territories and possessions.
  Request is coordinated by the DFAS DoD Banking
  and Credit Union Office.
• Solicitation is not required if a designated
  geographic franchise exists and credit union is
  able to accommodate request for additional
  services.
• If geographic franchise does not exist, the
  secretary of the military department concerned
  (or designee) will solicit proposals to obtain
  one.

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Overseas Financial Institutions (cont)

• Closures
• Early notification from command is paramount.
  Each country has different laws regarding
  compensation for local nationals employed by
  Community Bank and the credit unions. Additional
  severance pay may be required if notification is
  late.
• Notification must go through command channels.
  Service department BLOs must concur on
  documentation and submit to the DoD Banking and
  Credit Union Office for action.

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Questions ?
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