FREE Deposit Compliance Q & A Forum

Do you have burning questions related to deposit compliance?  Struggling with Electronic Funds Transfers, Truth in Savings Act, Regulation CC deposit delays, etc.?  If so, we’d love to have you join us on May 6, 2021, for our FREE Deposit Compliance Q & A Forum where we’ll answer questions such as:

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FREE Deposit Compliance Q & A Forum

Question: Is it okay for our lenders to accept deposits and bring them to the teller line?

Answer:  This isn’t necessarily prohibited, but we wouldn’t recommend it.  First, you are required to post your general funds availability policy where deposits are received and this could get tricky if deposits are being accepted at places other than the teller line.  Second, lenders would need to have “Member FDIC” signs on their desks as well.

Question:  We recently discovered an annual percentage yield (APY) for one of our accounts was inaccurate. How do you recommend handling this?

Answer:  Keep in mind, the regulation does provide a tolerance of .05%.  This tolerance, however, should not be used to knowingly inflate the APY because that could quickly turn into a UDAAP issue.  If your APY is outside this tolerance, you will obviously want to correct it on any affected disclosures, advertising, etc.  Many are surprised to learn Regulation DD does not require restitution/reimbursement for APY tolerance errors but you could choose to do so.  It’s really a customer service issue.

All you have to do is register for the Forum on our website and then start pre-submitting your deposit compliance questions to training@bankerscompliance.com (please put “May Forum” in the subject line).  We will answer as many of your questions as we can during the allotted hour.

See you there!!

Published
2021/04/02

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