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Tag Archive for: FIPCO

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News, Resources

Making a Case for Third-Party Loan Origination

By Jeff Schmid, CRCM

Jeff Schmid

Not long after FIPCO created a business model for shared compliance and risk management in 2019, the demand for shared loan processing and origination spiked. It only made sense as in the years that followed, we saw the lowest mortgage loan rates in nearly a decade. Unfortunately, our ShareFI services were not equipped to offer this assistance back then, even though our ShareFI team had more than twenty years of experience managing loan processing and origination departments in both large and small institutions.

Fast forward to 2025, and I think we will see the next cycle of low rates with high refinances, especially as a recession is possibly on the horizon. Think back to 2020 when loan processing departments across the country were swamped with loan
applications. It was very dynamic too because loan processors were mostly working remotely and the concept of PPP loans created quite a stir within our commercial departments. For the first time, we had to prioritize customers in both loan products. I am not sure if we have all recovered, but more importantly, I am not sure banks are ready for the next low-rate cycle. In this article, we explore the case of outsourcing third-party origination (TPO) to help you prepare.

The case for compliance: while most Loan Origination Software (LOS) vendors tout their systems as the most compliant with federal regulations, we all know it really comes down to knowledgeable staff making the right decisions. When you have an inexperienced staff who process less than five mortgages a month, will they be able to keep up loan demand next year while at the same time, keep your bank from regulatory scrutiny? TPO services can keep you compliant and so can ShareFI.

The case for staffing: look around and ask yourself, “do we have the same level of staffing as we did in 2020, even though loan demand has declined sharply?” If this is true in your bank, I offer you the concept of TPO services and saving your capital. After all, the next cycle will not last long and then you are back to overstaffed departments again. Or conversely, did you find a void in loan processing and now wondering where you are going to find talent to help you through the next cycle?

The case of backup: maybe you are part of the lucky few who are currently right sized with your loan processing department. But what happens when one or two processors, especially those who survived 2020, decide that being retired is much less stressful. We know it can take weeks, if not months, to find a replacement who is just as talented. And do not forget how expensive training can be. There is no additional staff training necessary when you deploy TPO.

The case for profitability: instead of purchasing all software origination modules, with extraordinarily high annual costs, consider a TPO partner who has made the capital investment and ride their wave into the next refinance craze. The costs associated with outsourced processing and origination do not have to rest with you as the lender. Consider passing on this cost to the borrower as compensation for speed and delivery.

The case for efficiency: well, readers get my point. Sharing professional services, whether its compliance, risk management, or loan processing, bank management teams across the country will find value in low cost, high yielding solutions. Whether it is today, tomorrow, or even next year, planning for TPO services now will give you the competitive advantage as demand begins to soar. You just simply need to make the case.

Whether you are a small bank with minimal origination or a large bank with high loan volumes, our ShareFI team is ready to partner you with the right TPO vendor. While this can be as simple as loan documentation preparation (which FIPCO has done for customers for years) or full-scale processing, we are ready to help you make the right decision.

To learn more about TPO or shared professional services, please contact Jeff Schmid at jschmid@fipco.com or 608-
441-1220. There is value in ShareFI.

Schmid is director of compliance and management services at ShareFI. FIPCO is a subsidiary of WBA and a WBA Gold Associate Member.

 

 

November 13, 2024/by Katie Reiser
https://www.wisbank.com/wp-content/uploads/2021/09/Triangle-Backgrounds_Lime-Green.jpg 972 1921 Katie Reiser https://www.wisbank.com/wp-content/uploads/2021/09/Wisconsin-Bankers-Association-logo.svg Katie Reiser2024-11-13 07:38:312024-11-13 07:38:31Making a Case for Third-Party Loan Origination
Member News, News

FIPCO Board of Directors Announcement

Dan De Jager

FIPCO would like to extend our deepest gratitude to Dan De Jager, Vice-President of Farmers & Merchants Union Bank in Columbus, WI, who has retired from the FIPCO Board of Directors as of August 21, 2024. De Jager has been an invaluable member of the board, serving with dedication and expertise from 2018 to 2024. FIPCO sincerely thanks him for his six years of outstanding service and commitment to FIPCO.

At the same time, FIPCO is excited to introduce our newest member of the FIPCO Board of Directors, Shelly Bucholtz. Shelly is the Loan Operations Officer at First Citizens State Bank in Whitewater, Wisconsin. FIPCO looks forward to the insights and contributions she will bring to the board.

Shelly Bucholtz

Please join FIPCO in wishing Dan all the best and in welcoming Shelly to the FIPCO Board.

August 27, 2024/by Katie Reiser
https://www.wisbank.com/wp-content/uploads/2021/09/Triangle-Backgrounds_Lime-Green.jpg 972 1921 Katie Reiser https://www.wisbank.com/wp-content/uploads/2021/09/Wisconsin-Bankers-Association-logo.svg Katie Reiser2024-08-27 07:54:482024-08-27 07:54:48FIPCO Board of Directors Announcement
Compliance, News, Resources

Executive Letter: WBA Municipal Borrowing Form Sets Accommodate New 20-Year Term

By Rose Oswald Poels

During the past 2023–2024 Wisconsin legislative session, 2023 Wisconsin Act 128 was signed into law which revised several banking-related areas of Wisconsin law, including a revision which extends the maximum maturity date of a promissory note issued by a municipality, county, or school district.

In particular, Act 128 revised Wis. Stat. Sec. 67.12 (12) as follows:

During the past 2023–2024 Wisconsin legislative session, 2023 Wisconsin Act 128 was signed into law which revised several banking-related areas of Wisconsin law, including a revision which extends the maximum maturity date of a promissory note issued by a municipality, county, or school district.

As a result of Act 128, the maximum maturity date of a promissory note issued to a municipality, county, or school district is now 20 years. In recent bank visits, I have fielded questions about whether this law has changed to allow banks to compete better with state programs and whether the current forms will work. The question related to whether the WBA municipal borrowing form sets offered through FIPCO accommodate the 20-year term now available under Wisconsin law is because an instructional page within the form sets references 10-years within its language.

Indeed, the current WBA municipal borrowing form sets will accommodate a 20-year loan term. These forms include the WBA 200-205 form sets and the WBA 220-225 form sets. The reference to “10-years” is only in the instructional cover page to each series and is not in the contents of the forms themselves which are executed with a municipal borrowing customer.

Each of the WBA municipal form sets listed above reference Wis. Stat. 67.12(12) within the forms’ language. Since Section 67.12(12) was the section revised by Act 128 to allow for a 20-year term, the WBA municipal borrowing form sets will accommodate a 20-year loan term.

Nonetheless, FIPCO is currently working on revisions to the WBA municipal borrowing form sets which include a revision to strike the reference of the “10 years” from the instructional cover page and change it to 20 years, changing any reference of “bank” within the forms to “financial institutions,” and adding other clarifying language. The revised forms are planned for release in the next month or two. Until such release, the current WBA municipal borrowing forms, WBA 200-205 form sets and the WBA 220-225 form sets, will accommodate a 20-year loan term.

August 15, 2024/by Katie Reiser
https://www.wisbank.com/wp-content/uploads/2021/09/Triangle-Backgrounds_Yellow-on-Light-Blue.jpg 972 1921 Katie Reiser https://www.wisbank.com/wp-content/uploads/2021/09/Wisconsin-Bankers-Association-logo.svg Katie Reiser2024-08-15 07:17:222024-08-15 07:17:22Executive Letter: WBA Municipal Borrowing Form Sets Accommodate New 20-Year Term
Member News, News, Resources

Committee Chair Spotlight: Shannon Grunewald

The following is a brief interview with Shannon Grunewald, loan operations officer at Waldo State Bank. Grunewald is chair of the 2023–2024 FIPCO Software Users’ Committee.

How did you first get into the banking industry?

I had just graduated from high school, working a part time job, trying to decide what I wanted to be when I grew up and an opportunity came up to work for a large bank in their post-closing department. After 14 years working in large banks, I decided that taking on a position at a small community bank was more my style. Who knew someday I would find Waldo.

Why did you decide to join a WBA committee? Why should others consider lending their time and expertise to shaping Wisconsin’s banking industry?

My supervisor at the time was ending his term on the committee and continuously expressed how important the connections he made were and how much fun he had. I loved the idea of being a part of suggesting enhancements to make all our lives easier. I now have a network of peers (I now consider friends) that I can bounce ideas off of or get suggestions for new products.

How has WBA facilitated the growth you have seen in your career and as a leader?

Ahead of the 2023 FIPCO Compliance Concierge Software & Compliance Forum this past October, FIPCO contacted me, as this year’s chair of the user committee, asking if I would be willing to do an opening speech and committee member introduction. I couldn’t say no, but as someone that has a fear of public speaking this was one of the hardest things I did this year. But the encouragement that FIPCO staff, my fellow committee members, and my coworkers showed me, made it in the end one of the easier things I’ve done.

As a banker, and as a leader, what is the most important lesson that you have learned?

That with the right people around you, anything can be accomplished. Regulations and HMDA will always be the death of me, but as long as I have a great team surrounding me, I will go on. Choose a job you love, and you will never have to work a day in your life. –Confucius.

Who (or what) motivates you to succeed?

Seeing my team learn and grow. If I have shared knowledge with someone and later see them share it with another, it’s the best feeling around.

December 20, 2023/by Hannah Flanders
https://www.wisbank.com/wp-content/uploads/2021/09/Untitled-3_Light-Blue.jpg 972 1920 Hannah Flanders https://www.wisbank.com/wp-content/uploads/2021/09/Wisconsin-Bankers-Association-logo.svg Hannah Flanders2023-12-20 08:33:492023-12-20 08:33:49Committee Chair Spotlight: Shannon Grunewald
News, Uncategorized

FIPCO Welcomes New Staff

Read more
February 4, 2022/by Jaclyn Lindquist
https://www.wisbank.com/wp-content/uploads/2021/09/Untitled-3_Blue.jpg 972 1920 Jaclyn Lindquist https://www.wisbank.com/wp-content/uploads/2021/09/Wisconsin-Bankers-Association-logo.svg Jaclyn Lindquist2022-02-04 13:50:332022-02-04 13:50:33FIPCO Welcomes New Staff
Row of digital locks with glowing lock in middle
News

The Evolution of Information Technology

Thank You, Ken Shaurette, for 13 Years at FIPCO!

By Hannah Flanders

On December 31, 2021 Ken Shaurette retired from FIPCO’s Information Security and Audit Services after 13 years with the company. Shaurette launched his IT career in 1976 after completing his associates degree in data processing. Over the past two decades, he has also garnered a collection of training courses through venders and trade schools as well as certifications by the National Security Agency (NSA) in Information Assessment Methodology. In 2008, Shaurette was hired at FIPCO to build the Information Security and Audit Service from the ground up as its director.

Shaurette shared reflections on how the industry has changed over his decades of experience. When his career began, data was stored centrally in large computer data centers. Slowly, the industry began to give more processing power and ability to manipulate data to users and as the data became increasingly decentralized, security professionals had to establish improved policies and information security programs that addressed data no longer being stored in a big computer center, but out at the desktops anywhere in the company.

As data collection and storage abilities improved, not only did it become more difficult for all the information to be properly secured, it became increasingly important. Regulations have been created today in order to meet the expectation that customer data is equally protected no matter the size of the bank. “Information security [must continue to be] part of our individual and our companies DNA” says Shaurette. “Without security controls, your business can’t grow quickly.”

Shaurette’s perspective has allowed him to help banks throughout Wisconsin protect themselves against serious attacks that could in turn affect growth, reliability, and profits. Shaurette notes that “when it comes to information security 80% is the same regardless of [the] industry when securing the data, 15% is unique to the [banking] industry, and probably 5% is the social atmosphere of [each bank].”

“Over the course of the years, his expertise and service have been greatly appreciated and well-respected by our customers and members,” says Pam Kelly, president of FIPCO. “His passion and unfailing dedication to information security and our members has helped hundreds of bankers keep critical data secure, avoid attackers, and meet the needs of their own communities. Thank you, Ken, for 13 years!”

In his retirement, Shaurette looks forward to spending time with his grandchildren, volunteering, and — he jokes — not writing audit reports. However, he leaves FIPCO customers with one last message in appreciation over that last 13 years, “I may be boating off into the sunset, but the sunrise of a new generation is transitioning behind me, and you will be left in very good hands with Rob Foxx. I’ll be waiting for you to show up for an information security peer group meeting or networking round table on the pontoon boat someday soon. Those that know me, the refreshments are always ready.”

January 4, 2022/by Hannah Flanders
https://www.wisbank.com/wp-content/uploads/2021/10/digital_cyber_security_banner-1.jpg 864 1152 Hannah Flanders https://www.wisbank.com/wp-content/uploads/2021/09/Wisconsin-Bankers-Association-logo.svg Hannah Flanders2022-01-04 13:44:432022-01-04 14:45:13The Evolution of Information Technology
News, Products

Bringing Call Centers into the Future

FIPCO partners with interface.ai

In this current world, customer connection comes at a premium. The pandemic changed many things and shifted customer behavior. Now customers who may have previously stopped by a branch to ask a question are seeking service through phone more and more. How can financial institutions manage the ever-increasing number of calls while still providing high-quality service?

FIPCO is proud to announce a new partnership with interface.ai. interface.ai’s artificial intelligence (AI)-Powered Phone Banking solves many of the problems faced by traditional call center, elevating the entire call center experience. The AI-Powered Phone Banking automates more than 60% of the financial institution’s call center calls using the industry’s first neural voice-powered AI assistant.

“We are thrilled to be able to partner with interface.ai to offer this world-class product to our customers,” said Pam Kelly, president of FIPCO. “We understand the need for effective service for everyone who calls an institution, while making sure call center staff are not overwhelmed and customers aren’t stuck waiting for help in a queue.”

The AI-Powered Phone Banking reduces call wait times, while increasing productivity and engagement. FIPCO and interface.ai will be hosting informational webinars on November 9 and 16 to demonstrate to capabilities of this solution.

To learn more about this solution and the upcoming demos, contact FIPCO Sales at fipcosales@fipco.com or 1-800-722-3498, option 5.

Upcoming Informational Webinars:

Date: November 9, 2021
Time: 12:30 PM – 1:30 PM CT

Date: November 16, 2021
Time: 11:30 AM – 12:30 PM CT

November 9, 2021/by Cassandra Krause
https://www.wisbank.com/wp-content/uploads/2021/09/Untitled-3_Blue.jpg 972 1920 Cassandra Krause https://www.wisbank.com/wp-content/uploads/2021/09/Wisconsin-Bankers-Association-logo.svg Cassandra Krause2021-11-09 14:15:532021-11-09 14:39:53Bringing Call Centers into the Future
Digital locks representing cybersecurity
News, Products, Resources

What Community Banks Need to Know About Ransomware Attacks

By Cassandra Krause 

With a recent uptick in activity, ransomware attacks are a form of cyberattack that has been prevalent in recent news — and for good reason. The effects can be detrimental in terms of monetary loss and reputational damage to the victim. Ransomware is a type of malicious software (a.k.a. malware) that usually encrypts a victim’s files, and the bad actors have upped their game to steal the data first, then threaten to also publish the data to the public. Criminals set their sights on businesses with the goal of extorting money, making community banks prime targets. 

Organized crime networks are becoming increasingly sophisticated. In general, the risk of getting caught for cybercrimes is much lower than for traditional crimes like robbery, and the financial gains are far higher. Ransomware developers write and sell the software to other bad actors for a cut of the profits when they deploy it and collect ransom payment, usually in the form of cryptocurrency, which is hard to trace. Compromised data may also be used to open fraudulent lines of credit. 

“The U.S. is in a ransomware crisis right now,” said Jeff Otteson, vice president of sales at Midwest Bankers Insurance Services (MBIS), a subsidiary of the Wisconsin Bankers Association. He explained that it has created a hard insurance market with carriers tightening up on internal control requirements such as multifactor authentication (MFA) for privileged users (users with the ability to install software or change security settings on critical systems) and encryption of backups. 

In their 2021 Cost of a Data Breach Report, IBM Security and the Ponemon Institute calculate that the average total cost of a data breach is $4.24 million, a 10% increase from 2020–2021. The per-record cost of personally identifiable information averaged $180. 

Prevention 

With the incredibly high stakes in mind, banks are dedicating significant resources to preventing malicious cyberactivity, both in terms of staff and money. Respondents to a 2020 Deloitte survey of financial institutions reported spending about 10.9% of their IT budget on cybersecurity on average, up from 10.1% in 2019. In terms of spending per employee, respondents spent about $2,700 on average per full-time employee (FTE) on cybersecurity in 2020, up from about $2,300 the prior year. 

“There is an industry-standard framework for ransomware prevention and all cybersecurity,” explained FIPCO’s Director InfoSec and Audit Ken Shaurette. FIPCO is also a WBA subsidiary. A good consultant will walk the bank through a comprehensive review of their network security, improving endpoint protection to replace traditional antivirus and endpoint detection solutions, including adding authentication improvements such as MFA, improved password strength, and protecting backups. As more and more of the digital tools that bankers utilize require users to download and install software and updates, depending on signature-based solutions for malware detection is not acceptable — it has become critical to safeguard user, file, network, and device-level activities. 

A bad actor gaining access to a bank’s data may encrypt the data and demand payment in exchange for granting access back to the bank. In this situation, having a data backup is essential.  

“The rule of thumb for data backups is 3-2-1,” said FIPCO Information Security and IT Audit Advisor Rob Foxx. “There should be three copies of all data stored on two different mediums. One of the copies should be stored off site.” 

Ransomware prevention is only one part of a complete cybersecurity system. Experts agree that early detection of unusual activity within a system can help keep a minor incident from quickly escalating into a major incident like a ransomware threat. 

“Ransomware isn’t the first attack,” said Wolf & Company, P.C. Manager of the I.T. Assurance Group Sean Goodwin, who recently presented at WBA’s Secur-I.T. Conference. “Ultimately, it’s on I.T. to put controls in place because an employee will inevitably fall for a phishing email. It becomes a question of whether we can catch that quickly.” 

Social engineering remains the greatest concern; it’s easier for bad actors to trick an employee rather than break through a firewall. Verizon’s 2021 Data Breach Investigations Report found that almost half of the breaches in the financial services industry involved internal actors committing various types of errors. The report stated that the financial sector frequently faces credential and ransomware attacks from external actors, 96% of which are financially motivated (followed by small percentages of motives of espionage, grudge, fun, and ideology). 

Goodwin emphasized that I.T. must be able to act quickly when there’s an indication that someone is accessing something they don’t normally access. “Prevention is ideal. If we can prevent it, that’s best-case scenario, but if not, early detection becomes critical,” he said. This area of solution, known as endpoint detection and response, is rapidly becoming a key point of protection from ransomware and all other malicious events. 

Establishing an incident response program within a bank is an important part of the overall cybersecurity program. 

Preparation 

Creating a culture of cybersecurity awareness throughout the bank is important, so that bank employees are prepared for an incident. Employee training on what to do in the event of an attack should be standard practice. Making security part of the organization’s DNA is a best practice. 

“Every bank needs an incident response plan, and that needs to be approved all the way up through the board. Part of this plan is notification of incidents to the insurance carrier,” said MBIS’s Otteson. 

FIPCO’s Foxx emphasized that the roles and responsibilities in the incident response plan must be clearly defined, and banks should revisit their plan regularly.  

“As the insurance agent, I’m the first call a bank makes when there’s an incident,” said Otteson. “It’s important that banks choose to work with an agency that understands cyber insurance.”  

MBIS insures about 220 banks and has access to a large number of carriers that provide the right coverage for their customers. Otteson recommends reporting all incidents as even a minor incident could result in a claim down the line and having reported that incident when it occurred is key to a successful claim. He says to keep in mind that the owner of the data is liable for it whether the incident occurred in house or with a vendor the bank shared customer data with. 

Mitigation 

It’s important to work with the insurance carrier to ensure that all the bases are covered and that the vendors who participate in the response are approved. Not using the cyber insurance carrier’s approved vendors may result in expenses not being covered under the insurance policy. In the event of a ransomware attack, the insurance agent or bank will immediately notify the insurance carrier. Beazley, a carrier partner of MBIS, maintains a 24/7 helpline, which has become common with other carriers as well. Knowing how to report incidents, when to report, and what to expect is key. 

Holidays and weekends are prime times for ransomware attacks: employees who are in a rush to leave may be more likely to click on a bad link, and with employees away from work, it’s easier for the bad actors to get into the network. Even if a problem is detected, it’s more likely that staff who could help put a stop to the attack may be on vacation or unavailable, buying the criminals more time to take over. 

As soon as a cyber liability claim is made, the insurance carrier’s pre-approved vendors come into play.  

“Nobody has the resources in house to effectively manage ransomware attacks,” said Foxx, who has experience working both within a bank and as an external auditor and consultant. The specialization of skills and the amount of people needed to perform adequate analysis and remediation are so significant that even large banks will not have all the players they need on staff. 

If a bank’s data becomes encrypted and made inaccessible, a vendor such as Tetra Defense would be engaged on forensics. Managed endpoint detection and response vendors such as Cynet can help from detection and prevention to response, including providing digital evidence for a vendor performing forensics. Meanwhile, a vendor such as Coveware would handle ransom negotiations with the criminals. Wolf & Company, P.C.’s Goodwin said that you don’t really know who’s on the other side of the transaction — some criminals may be willing to negotiate and others not. He referred to ransomware as a “niche space in cybersecurity that is now getting more attention.” The criminal organizations involved in these types of attacks in some ways act like a legitimate business in that they rely on their reputation and may even have customer service departments — if they fail, it will hurt their chances of getting more business in the future.  

Typically, in the event of a ransomware attack, a legal firm will handle communications and PR for the bank — putting a statement on the bank’s website, assisting staff with customer phone calls, and determining whom to notify. Getting legal involved early protects all communications and discovery with attorney-client privilege. The requirements for notification vary from state to state, and a bank may have customers in multiple states or even other countries, making the expertise of a legal team invaluable. The language used in communications matters, as the term “breach,” for example, can have different legal implications and potentially create larger issues than terms like “incident,” “situation,” or “event.” Education of staff far in advance using regular testing of the plan is a key factor in mitigating an incident. Inappropriate statements made by employees on social media or even at informal social gatherings can have severe ramifications for the bank. 

Follow Up 

While anyone who experiences a ransomware attack may be eager to breathe a sigh of relief and move on when it is over, it is essential to review the incident and revise the bank’s incidence response plan. Assessing what went well and what needs to be improved are critical steps.  

Goodwin also warns that victims of ransomware are commonly re-targeted. A Cybereason study found that 80% of organizations that previously paid ransom demands confirmed they were exposed to a second attack. He said that once a company has paid a ransom it is known that (1) you were compromised, (2) you do not have proper backups of your files, and (3) you were willing to pay. 

Summary 

Cyberattacks are the biggest risk to a financial institution — even surpassing the risk of past-due loans. The cost of a ransomware attack can be astronomical, with many factors contributing to the price tag, including vendor fees and staff hours to resolve the issue; the cost to inform customers and offer identity or other protections; the loss of destructed data; and the down time of the business. All of this, followed by the loss of customers’ trust (and subsequent loss of their business), has the potential to put a community bank out of business.  

There are safeguards banks can put in place, including a sound incident response plan, improved monitoring with better endpoint detection and response, cyber liability coverage, and employee education. FIPCO, MBIS, and a wide range of WBA Associate Members are ready to support banks in keeping their data and that of their customers safe.  

October 20, 2021/by Cassandra Krause
https://www.wisbank.com/wp-content/uploads/2021/10/bigstock-193480438.jpg 729 1600 Cassandra Krause https://www.wisbank.com/wp-content/uploads/2021/09/Wisconsin-Bankers-Association-logo.svg Cassandra Krause2021-10-20 13:41:012021-10-20 13:41:01What Community Banks Need to Know About Ransomware Attacks
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Because these cookies are strictly necessary to deliver the website, refusing them will have impact how our site functions. You always can block or delete cookies by changing your browser settings and force blocking all cookies on this website. But this will always prompt you to accept/refuse cookies when revisiting our site.

We fully respect if you want to refuse cookies but to avoid asking you again and again kindly allow us to store a cookie for that. You are free to opt out any time or opt in for other cookies to get a better experience. If you refuse cookies we will remove all set cookies in our domain.

We provide you with a list of stored cookies on your computer in our domain so you can check what we stored. Due to security reasons we are not able to show or modify cookies from other domains. You can check these in your browser security settings.

Other external services

We also use different external services like Google Webfonts, Google Maps, and external Video providers. Since these providers may collect personal data like your IP address we allow you to block them here. Please be aware that this might heavily reduce the functionality and appearance of our site. Changes will take effect once you reload the page.

Google Webfont Settings:

Google Map Settings:

Google reCaptcha Settings:

Vimeo and Youtube video embeds:

Privacy Policy

You can read about our cookies and privacy settings in detail on our Privacy Policy Page.

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