FDIC Common Deposit Violations

In November, we had the pleasure of attending the 2019 Iowa Bankers Association Compliance Conference.  One of the breakout sessions addressed common errors and findings from the FDIC.  Whether you are FDIC regulated or not, any time you have access to a regulator’s common violations, it’s a great opportunity to review them and ensure you are not making the same mistakes at your financial institution.

  1. Truth In Savings Act

Many of the common violations noted had to do with system updates.  If you customize your software, for example, so that fee terminology on your periodic statements matches your account opening disclosures, make sure when you get a system update that those changes are still in place.  Financial institutions often don’t think to check this and unfortunately, examiners are typically the ones to find the problem.

2. Electronic Fund Transfer Error Resolution

The FDIC continues to see the following violations:

  • Employees not immediately sending error notices to the appropriate department for timely investigation and resolution;
    • Requiring a consumer to provide a written or signed confirmation of the error before initiating an investigation;
    • Requiring a police report or a signed fraud affidavit before initiating an investigation;
    • Requiring the consumer to work with the merchant prior to investigating an EFT error; and,
    • Not notifying consumers when an investigation has been completed and giving them the results of the investigation.

Be sure to check out our webinars that are available On Demand.  We offer webinars on a variety of deposit topics including both the Truth in Savings Act and Regulation E: Errors & Disputes.


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