current management liability issues of interest to ... management liability issues of interest to...
TRANSCRIPT
Current Management Liability Issues of Interest to Community Bankers
Account Takeover, Allocation of Loss and Loss Prevention Strategies
April 8, 2015 12:00 – 1:00 p.m.
Table of Contents
Presentation Speaker Bios
John L. Bley, Foster Pepper PLLC Peter Marchel, Marchel & Associates Risk Consulting Yan Perng, Foster Pepper PLLC
Presented by:
Current Management Liability Issues of
Interest to Community Bankers
Account Takeover, Allocation of Loss and Loss Prevention Strategies
April 8, 2015
Presented by: John L. Bley, Foster Pepper PLLC Peter Marchel, Marchel and Associates Risk Consulting Yan Perng, Foster Pepper PLLC
Today’s Presentation Will Discuss
Account Takeover Laws Risk Mitigation Strategies Transferring Risk of an Account Take Over Event: Type and
Sufficiency
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Disclaimer...
This presentation gives overviews and summaries of otherwise very complex and detailed banking laws and regulations.
Depending on the facts and circumstances of a particular matter, the statements in this presentation may or may not specifically apply.
The presenters and their companies make no express or implied warrantees regarding the accuracy of the information presented and directs the users of this information to seek advice from counsel of their choosing regarding any particular matter generally or specifically addressed by this presentation.
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Overview of an Account Takeover event:
Bank receives a request via internet to execute a wire transfer on behalf of its customer.
Bank wires funds as directed. Customer contacts bank to notify them they did not authorize the wire
transfer.
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General Rule: The Electronic Funds Transfer Act (for consumers) and Article 4A of the Uniform Commercial Code allocate the risk of loss for unauthorized wire transfers to the bank provided prompt notice is given to the bank.
Exception: On commercial wires the risk of loss can shift to the customer if the bank can show: A commercially reasonable security procedure is in place and The bank accepted a payment order in good faith and in compliance with the
security procedure.
UCC Section 4A-202 (RCW 62A.4-202)
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Account Takeover Applicable Laws
Statutory law in Washington hasn’t changed substantively in decades Probably not an issue of amending the forms No silver bullet exculpatory language
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Account Takeover Applicable Laws (cont.)
Standard for “Commercially Reasonable” Not the best available, just needs to be reasonable for the particular customer
and the particular bank. Patco Construction Co. v. People's United Bank, 684 F.3d 197 (1st Cir. 2012).
Deemed reasonable if: the security procedure was refused by the customer; and the customer expressly agreed in writing Choice Escrow & Land Title, LLC v.
BancorpSouth Bank, No. 13-1879 (8th Cir. June 11, 2014).
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Account Takeover Applicable Laws (cont.)
FFIEC Pronouncement – Supplement to Authentication in an Internet Banking Environment, June 28, 2011
Knowing a “Commercially Reasonable Security Procedure” when I see it Difficult to avoid litigation in material cases since the parties will dispute the
commercial reasonableness of the security procedure A battle between experts
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Account Takeover Applicable Laws (cont.)
“Security Procedure” standard changes relative to the ongoing sophistication of the fraudsters System of layered security – Use of different controls at different points in the
transaction process so weakness in one control can be compensated for by the strength in a different control Dual customer authorizations Out-of-bank verification procedures “Positive pay” processes Debit locks Transaction value thresholds
Ongoing risk assessment to insure security procedures remain current
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Risk Mitigation Strategies
Best practices Deposit agreements should reference security procedures (If not, your forms
are profoundly out-of-date) Communicate your security procedures in a constantly current brochure and
incorporate by reference the brochure in the deposit agreement or amended deposit agreement
Implement internal audit procedures to assure bank personnel are following security procedures
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Risk Mitigation Strategies (cont.)
Risk Mitigation Strategies (cont.)
Best Practices Understand your customer’s needs and systems Monitor customer transactions and analyze and communicate with customer
regarding non-routine transactions Make sure your customer understands your security procedures If customer declines some of the security procedures
Inform the customer of the risks and get it in writing Assess the risks and decide whether or not to continue to serve the customer
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Mandiant’s Mtrends 2015: A View From the Front Lines
Across the Cyber Threat Landscape Cyber threat actors are exploiting networks for an ever-widening array of economic and political objectives.
NUISANCE
DATA THEFT
CYBER CRIME
HACKTIVISM
DESTRUCTIVE ATTACK
Objective Access &
Propagation Economic,
Political Advantage
Financial Gain Defamation,
Press & Policy Disrupt
Operations Example
Botnets & Spam Advanced
Persistent Th t G
Credit Card Theft Website
Defacements
Delete Data
Targeted
Character Often Automated Persistent Frequently
Opportunistic
Conspicuous Conflict Driven
APT Phishing
78% of observed phishing emails were IT or security related, often attempting to impersonate the targeted company’s IT department or an anti-virus vendor
72% of phishing emails were sent on weekdays
Mon
Tue
Wed
Thur
Fri
Sat
Sun
Time from Earliest Evidence of Compromise to Discovery of Compromise
205 median number of days that threat groups were present on a victim’s network before detection
24 days less than 2013
Longest Presence: 2,982 days
How Compromises Are Being Detected
31%
victims discovered the breach internally
69% victims notified by an external entity
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Risk Factors
Entity
Management
Employment
Crime / EE Theft
Fiduciary / Benefits
Errors & Omissions
Cyber
Commercial General Liability
Regulatory / Stakeholder
Employee / Regulatory
First Party &Third Party
Lending / Other
Beneficiaries
Employee / Other
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Insurance Coverages
RECOGNIZE YOUR POLICY LIMITS AND HOW THEY WILL APPLY
Management Liability
Errors & Omissions (Bankers Professional Liability
Cyber Liability
Account Take Over
Crime Bond
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Errors & Omissions (Bankers Professional Liability)
Protection for a company and its employees from claims alleging negligence in performing or failing to perform professional services offered to its customers.
No standard policy language - coverage will differ depending on insurance company.
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Crime Bond
Employee Infidelity Premises Risk (loss or damage resulting from theft) Cash in Transit Forgery or Alteration (checks and securities) Counterfeit Currency Damage to Offices and Content
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Cyber Loss Exposures
Insurance Company (Second Party)
First Party
Bank
-Damaged hardware, software and computer networks
-Comprised or Stolen data and cyber extortion -Business interruption and extra expenses -Post-breach expenses -Reputational damages
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Insurance Company (Second Party)
Third Party Customer
Trading Partner Third party exposure
First Party Bank
Customer v. Trading Partner Invasion of privacy, breach of contract Network security E-mail liability Damage to 3rd party Libel network from data Slander breach trademark, copyright Could also implicate D&O and E&O
Liability
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Cyber Loss Exposures
Cyber Liability – Access to Resources
Remediation expenses
Notification expenses
PR expenses
Fines & penalties
Third party
Experienced Advice
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Data Breach Life Cycle
Access the Problem
• Discover breach • Contain losses,
secure area • Alert preparedness
team • Notify law
enforcement • Notify regulators
Engage External Resources
• Alert vendor • Call forensics team • Alert public
relations (internal or external)
Comply with Notification
• Draft and send
notification • Active call center • Public disclosure (if
appropriate)
Manage Ongoing Business
• Continue assuring
customers • Continue data
systems monitoring • Resume business
as usual
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Placement of Risk – example 1
Bond • Employee Infidelity • Premises Risk (loss or
damage resulting from theft)
• Cash in Transit • Forgery or Alteration
(checks and securities) • Counterfeit Currency • Damage to Offices and
Content
Computer Crime Insurance Policy • eFraud • Computer Fraud
Services
Takeover Endorsement • Commercial Account • Retail Account
Cyber Policy • Privacy Breach (1st party) • Privacy (3rd party) • Digital Media Content (3rd party) • Cyber Extortion Event (1st party)
• First Party Insured Event
Endorsement • Business Interruption • First Party Expense
• Designated Defense Counsel
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Placement of Risk – example 2
Bond • Computer Crime Rider • Email Initiated Funds
Transfer Fraud Rider • Electronic Funds Transfers
Rider
Computer Crime Rider • Computer Systems Fraud • Fraudulent Electronic
Programming • Voice Initiated Transfer Fraud • Telefacsimile Transfer Rider • Destruction of Data or
Programs by Hacker • Destruction of Data or
Programs by Virus
Cyber • Network and Information Security
Liability • Communications and Media Liability • Regulatory Defenses Expenses • Crisis Management Event Expenses • Business Interruption and Additional
Expenses
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Placement of Risk – example 3
Bond • Computer Crime Rider • Email Initiated Funds Transfer
Fraud Rider • Electronic Funds Transfers Rider
Computer Crime Rider • Computer Systems Fraud • Fraudulent Electronic Programming • Voice Initiated Transfer Fraud • Telefacsimile Transfer Rider • Destruction of Data or Programs by
Hacker • Destruction of Data or Programs by
Virus
Cyber • Content Injury Liability • Privacy Injury Liability
• Privacy Injury Claims • Privacy Regulation Proceeding
• Network Security Liability • Public Relations Event Expense • Network Extortion • Loss of or Damage to Insured Entity’s
Network • Business Interruption and Extra Expense
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Mitigating Cyber Expenses
Questions to Ask About Insurance: What are the right limits? How do I pick the right coverage / company? What happens when a claim occurs?
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Factors When Considering Policy Limits
How many records does the bank have? Does the cyber policy have separate limits or are the limits shared
with other coverages (management liability, employment liability, professional liability)?
Size and location of the bank and its customers. Customer profile.
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Key Takeaways
Implement an account takeover security procedure Conduct ongoing assessment
Risks Ability to mitigate risk
Know your customer’s risk profile and security procedures Make a security procedure brochure and incorporate it by reference
into your deposit agreement; updates to the brochure require signed acknowledgement from the customer
Waivers from your security procedure requirements should be in writing after informing the customer of the risk
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Key Takeaways (cont.)
Know your insurance program. Know your limits. Review policy and limits annually. Know how to report a claim. Know how to interact with the insurance company.
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Thank you!!
Make it a great 2015!
John L. Bley Yan Perng
FOSTER PEPPER PLLC 1111 Third Avenue, Suite 3400
Seattle, WA 98101-3299 Phone: 206-447-4400 [email protected] [email protected]
www.foster.com
Peter Marchel Marchel & Associates Risk Consulting
Phone: 425-788-4349 Mobile: 206-940-5992
Fax: 425-788-0263 [email protected]
www.Marchelassociates.com
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SEATTLE T 206.447.8915
F 206.749.2115
SERVICES
Business Financial Institutions (Chair)
PRACTICE OVERVIEW John chairs the firm’s Financial Institutions practice and his practice includes regulatory intervention, regulatory compliance and enforcement prevention, regulatory relations, legislative relations, expert witness testimony, strategic planning, corporate governance, and mergers and acquisitions.
Regulatory Intervention. Represent financial institutions (banks and non-banks) before federal and state financial institutions regulators concerning pending or existing regulatory enforcement actions, these include either "safety and soundness" or "consumer compliance" actions. Services include (a) drafting responses to reports of examination, (b) negotiating the elements of cease and desist orders, (c) advising boards concerning implementation and compliance strategies with such orders, (d) negotiating civil money penalty and license revocation orders, (e) devising management work plans and other strategies designed to satisfy and lift regulatory orders.
Regulatory Compliance and Enforcement Prevention. Practice is similar to "Regulatory Intervention" except it is preventative in nature. Work with management and boards to identify and correct safety and soundness or compliance issues before such issues become subject to enforcement actions. Such issues include but are not limited to compliance strategies with numerous pronouncements on (i) safety and soundness matters such as lending limits rules, credit quality policies, loan portfolio risk management pronouncements and anti-money laundering laws and rules and (ii) consumer compliance matters, primarily in the residential and consumer lending area, including laws dealing with truth-in-lending, truth-in-savings, RESPA, safekeeping of customer information, sharing of customer information, and applicable state consumer protection laws and licensing regimes such as the Washington Mortgage Broker Practices Act and the Consumer Loan Act.
Regulatory Relations. Assist management with regulatory approvals for new banks, bank holding companies, trust administration, non-depository operating subsidiaries, sub-chapter S conversions and other such activities. Assist financial institutions and their trade associations influence the administrative rulemaking process.
Legislative Relations. Assist clients and their trade associations draft bills and devise advocacy strategies concerning proposed legislation before state and federal legislative bodies.
John L. Bley MEMBER
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John L. Bley MEMBER
SEATTLE T 206.447.8915 F 206.749.2115 [email protected]
Expert Witness Testimony. Provide consulting and testimony services as an expert witness in the areas of predatory lending, corporate governance, audit committee best practices and internal audit, securities fraud, FINRA arbitrations, state and federal regulatory safety and soundness enforcement processes and consumer compliance enforcement processes.
Strategic Planning. Facilitate board and/or management strategic planning initiatives for bank or commercial enterprises. Such processes are tailored to the needs and desires of the client but can include (a) devising, implementing, and analyzing board questionnaires (b) interviewing board members and members of the CEO's direct reports to determine board and management's view of the strengths, weakness, opportunities and threats confronting the organization, (c) facilitating board and/or management strategic planning sessions, tailored to the scope and needs of the client, (d) working with management and the board to implement "Strategic Action Plans" to facilitate implementation of the strategic strategies identified during the strategic planning sessions.
Corporate Governance. Advise on sound governance procedures especially in the areas of best audit committee practices and codes of ethics, focusing primarily on small (less than one billion dollars) non-public banks.
Mergers and Acquisitions. Assisting in the negotiation of mergers and branch acquisitions, including drafting and negotiating agreements and securing applicable regulatory approvals.
REPRESENTATIVE WORK
− Negotiated and drafted acquisition documents for community bank transactions. − Defended numerous federal and state regulatory investigations and enforcement orders. − Negotiated and drafted numerous marketing and servicing agreements on behalf of third party service providers of financial
institutions. − Facilitated numerous strategic planning processes for boards of directors and executives of community banks. − Acted as expert witness on bank governance and securities fraud litigation in federal and state litigation and FINRA arbitrations.
RECOGNITION
− The Best Lawyers in America® - Banking and Finance Law, 2013-2015 − Best in the Business: Leading Lawyers in the Puget Sound Region, Seattle Business magazine
+ Banking and Finance, 2013-2014
ACTIVITIES − Washington Finance League − Conference of State Bank Supervisors − American Bar Association, Business Law, Member − Washington Bar Association, Business Law, Member − RiverBank, Director and Audit Committee Chair − Youth Softball Coach
QUOTED − "Empowering Consumers is Consumer Protection," Testimony before Washington State Senate Financial Institutions, Housing &
Consumer Protection Committee, February 2005
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John L. Bley MEMBER
SEATTLE T 206.447.8915 F 206.749.2115 [email protected]
PUBLICATIONS − “So, What Are you Going to do Next?” Community Bankers of Washington Quarterly, Winter 2014 − “Credit Crisis Cause and Effect – What to Expect for Northwest in 2009,” Foster Pepper News Alert, November 2008 − “When State Regulators Come Knocking,” Co-Author, Scotsman Guide, October 2009 − “Empowering the State System - State Regulators Support Initiatives to Reduce Regulatory Burden,” The IntegraAdvisor,
August 2004 − “Supporting State Banking Systems: A Dedicated Approach to Economic Vitality,” The IntegraAdvisor, February 2003 − “Are You Ready for the Regulators? Economic Uncertainty Demands Proactive Management of Credit Risk,” IntegraAdvisor,
July 2002
PRESENTATIONS − “Creating and Implementing Your Cyber Response Plan,” Current Management Liability Issues of Interest to Community
Bankers series, Co-Presenter, November 2014 − “The Honorable Privilege of Serving as an Outside Director of a Community Bank: Practical Tips and Best Practices,” Speaker,
Community Bankers of Washington: 24th Annual Membership Convention & Trade Show, September 2014 − “Retribution: What FDIC Enforcement and Receivership Actions Tell Us about the Stand or Care,” Speaker, Washington
Bankers Association: Northwest Executive Leadership Conference, September 2014 − “Interactive Director Self Evaluation,” Speaker, Conference of State of Bank Supervisors (CSBS) Bank Directors Seminar,
September 2013 − Foster Pepper Bankers Briefing, Moderator, 2008-2014 − “Bank Audit Committee Best Practices,” Speaker, Oregon Bankers Association Directors College, February 2012 − “General Session - Legal Panel,” Panelist, CBW 21st Annual Convention and Trade Show, September 2011 − “An Interactive Mock Board Session: Governance & Audit Committee Best Practices,” Speaker, Oregon Bankers Association
106th Anniversary Convention, June 2011 − “CSBS State-Federal Supervisory Forum,” Speaker, 2011 CSBS State-Federal Supervisory Forum, May 2011 − “Update on State Charter Banks and the Anatomy of a Bank Failure,” Speaker, 2010 Real Estate & Land Use Seminar, April
2010 − “Board Governance Best Practices,” Speaker, Northwest Bank Directors College, February 2010 − “Interactive Mock Board Session – Meeting with the Regulators: Mock Board Case Study Issues,” Panelist, GSBC and CSBS
Bank Directors Seminar, September 2009 − Moderated Regulator Panel, Western Independent Bankers (WIB) Annual CFO, Investments and Operational Risk Conference,
May 2009 − “Interactive Mock Board Session,” Speaker, WIB/AABD Annual Directors Conference, November 2008 − “Directors & Regulatory Hotspots,” Presenter, Western Independent Bankers Webinar, September 2008 − “The Status of Banking in Washington,” Speaker, 2008 Commercial Lending Institute, September 2008 − “Directors & Red Flags in Board Reports,” Presenter, Western Independent Bankers Webinar, April 2008 − “Mastering Disaster - Dealing with Problem Credits,” Moderator, March 2008 − “Board Governance Best Practices,” Presenter, Northwest Bank Directors College, February 2008 − “Director Compensation & Executive Compensation in Today's Environment,” Speaker, WIB/AABD 2007 Annual Bank
Directors Conference, November 2007 − “Corporate Structures,” Speaker, Bank Directors Seminar, September 2007 − “Directors and Regulatory Hot Spots,” Speaker, The Western Independent Bankers Directors Series 2007, June 2007 − “The Director's Role in Compliance,” Speaker, The Utah Bankers Association Current Issues in Banking for Bank Directors,
April 2007
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John L. Bley MEMBER
SEATTLE T 206.447.8915 F 206.749.2115 [email protected]
− “BSA Overview on Enterprise Risk Assessment,” Speaker, Northwest Summit for Financial Professionals, March 2007 − “Where the $OX Might Not Fit,” Speaker, Small Bank Board Governance and Audit Committee Best Practices, Northwest Bank
Directors College, February 2007 − “Challenges in the Board Room: Fiduciary Duty, Ethics and Legality,” Speaker, WBA CEO/Bank Directors Conference,
December 2006 − “Today’s Regulatory Environment,” Speaker, Today’s Regulatory Environment: Basic Real Estate Finance, November 2006 − “Managing Payment Shock: Review and Commentary on the Interagency Guidance on Nontraditional Mortgage Products Risks,”
Speaker, OBA Compliance Committee, November 2006 − “West Coast Law Update -- State Consumer Lending Enforcement Actions,” Speaker, WIB/CBA 28th Annual Regulatory
Compliance Conference, October 2006 − “The Board's Role in Compliance,” Speaker, CSBS Bank Directors Seminar, September 2006 − “Enterprise Risk Assessment,” Speaker, FDIC Bank Secrecy Act/Anti-money Laundering Seminar, September 2006 − Bank Regulatory Panel, Moderator, WICBA Annual Membership Convention, September 2006 − “Washington Bankers Association: Key Regulatory Issues Affecting Directors,” Presenter, Regulatory Issues Impacting
Directors, September 2006 − “Corporate Governance for Credit Unions,” Presenter, NASCUS 40th Annual Conference & Symposium, August 2005 − “Agent Assisted Lending & FDIC Audits Presentation and Dialogue,” Presenter, 2005 CFSA Annual Meeting, March 2005 − “What Isn't Predatory Lending,” Presenter, 2004 CFSA Annual Meeting, February 2005 − “Agent Assisted Lending & FDIC Audits Presentations and Dialogue,” Presenter, 2004 CFSA Annual Meeting, February 2004 − “Current Privacy Issues,” Presenter, 2003 AFSA/NACCA Administrators/Industry Day, September, 2003 − “Agency Audits: What Are The Traps?” Presenter, Payday Lending Regulatory Summit, June, 2003 − “The Sarbanes-Oxley Act of 2002,” Presenter, Western Independent Bankers 2003 Annual Cashiers/CFOs Conference
Workshops on Directors & the Audit Committee, June 2003 − “The Sarbanes-Oxley Act of 2002,” Presenter, Western Independent Bankers 46th Annual Conference, March 2003 − “Agency Audits: What are the Traps?” Presenter, 2003 CFSA Annual Meeting, February 2003 − “The Sarbanes-Oxley Act of 2002,” Presenter, Public Company Accounting Reform and Investor Protection, February 2003 − “Bank Directors Duties from a Legal Perspective,” Presenter, IntegraAdvisors, August 2002 − “Public Company Accounting Reform and Investor Protection, The Sarbanes-Oxley Act of 2002,” Presenter, IntegraAdvisors,
August 2002
EXPERIENCE − Foster Pepper PLLC
+ Member, 2009-Present + Of Counsel, 2006-2008
− IntegraAdvisors, LLC, CEO, 2002-2006 − Washington State Department of Financial Institutions, Director, 1993-2002 − Washington State Division of Banking
+ Supervisor of Banking, 1991-1993 + Deputy Supervisor of Banking, 1988-1991
− Graham & Dunn PC, Attorney, 1985-1988
BAR ADMISSIONS − Washington, 1985
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John L. Bley MEMBER
SEATTLE T 206.447.8915 F 206.749.2115 [email protected]
EDUCATION
− J.D./M.B.A., Willamette University, 1985 − B.A., Pacific Lutheran University, 1980
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Peter M. Marchel, Esq. JD, MBA, CDR, RPLU, CPCU, AIM, AIS President, Marchel & Associates Risk Consulting (425) 788 – 4349 [email protected] Peter Marchel is President and Founder of Marchel & Associates Risk Consulting a Pacific Northwest based independent insurance advisor for banks, credit unions, insurance companies, insurance agencies and companies seeking capital from the market. Some of the Services offered: Risk Consulting, prevention as well as Insurance review and analysis, Insurance Placement, Program Development, Insurance Management Issues, Policy Enforcement (Claims Advocacy, Mediation and Arbitration) and Expert Witness Testimony. Peter has more than 24 years experience in Legal and Insurance matters. His background is unique; from working on Insurance Opinions as a former Law Clerk to a State Supreme Court Justice, to arguing insurance cases before the court on behalf of both defendants and plaintiffs as a Trial Attorney. His experience as in-house Counsel and General Counsel for both insurance companies and insurance brokerages has brought a unique and valuable perspective to his clients. Peter, consults with clients and their counsel on complex claims, as well as assistance with policy language, structuring program audits, and development of financial risk solutions. Peter has developed D&O programs for over 200 different publically traded companies in the United States and Canada. Peter holds numerous insurance designations (RPLU, CPCU, AIM, and AIS). Peter has also taught Finance, Investments and Insurance Law at the College level at Crichton College, Memphis, TN., where he served as an adjunct professor.
SEATTLE T 206.447.6233
F 206.749.2140
SERVICES Business
PRACTICE OVERVIEW Yan is a first year associate in the firm’s Business and Intellectual Property practices.
RECOGNITION − 2014 AIPLA Giles Sutherland Rich Memorial Moot Court Competition
+ Best Appellate Brief + Western Regional Competition Winner + National Competition Semifinalist
− Finalist, 2012 Peterson Wampold Rosato Luna Knopp Mock Trial Competition − Best Brief & Semifinalist, 2011 Hillis Clark Martin & Peterson Appellate Advocacy
Competition
ACTIVITIES − Seattle IP Inn of Court, Associate Member, September 2014-Present − Snohomish County Legal Services, Paralegal Volunteer, 2011 − Asia Pacific American Legal Resource Center, Legal Intern Volunteer, 2011
PUBLICATIONS − “NLRB: Employers Cannot Ban Employees From Using Company’s Email System for Union-
Related Communications,” Co-author, Foster Pepper News Alert, December 2014
EXPERIENCE − Foster Pepper PLLC
+ Associate, 2014-Present + Summer Associate, 2013
− U.S. Court of Appeals Federal Circuit, Judicial Clerk Extern for the Hon. Chief Judge Randall Rader, 2013
− University of Washington Center for Commercialization, Copyright and Trademark Legal Extern, 2012
− Patterson Buchanan Fobes Leitch & Kalzer, Inc., P.S., Summer Associate, 2012
Yan Perng ASSOCIATE
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Yan Perng ASSOCIATE
SEATTLE T 206.447.6233 F 206.749.2140 [email protected]
− Center for Advanced Study & Research on Intellectual Property, Teaching Assistant, 2012-2013 − Office of Oregon Senator Jeffrey Merkely, Legislative Assistant Intern, 2011 − Taiwan Legislature & National Chiao-Tung University, Research Assistant, 2010 − Asia FM (Broadcasting Network), Radio DJ, 2008-2011 − Videoland Television Network, Performing Artist, 2004-2008
BAR ADMISSIONS − Washington, 2014
EDUCATION
− J.D., University of Washington School of Law, 2014 + Moot Court Honor Board + VP of Professional Development, Minority Law Student Association + Entrepreneurial Law Clinic + Technology Law and Policy Clinic
− B.S. Biochemical Engineering, National Taiwan University, 2008
LANGUAGES − Chinese (Mandarin), fluent
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