In May, the CFPB issued Interagency Guidance Regarding Deposit Reconciliation Practices to provide banks a clearer picture as to what they are supposed to be doing to avoid customer harm. There are a number of scenarios that could lead to a discrepancy between what a customer deposits into an account and the amount that is actually credited by the bank. Inaccurate deposit slips, encoding errors or poor image captures can all lead to discrepancies that need to be reconciled by the bank.
Credit discrepancies can raise issues under Reg CC, the FTC, UDAAP, etc., and it is important that banks develop policies, procedures and practices to manage the risk and avoid consumer harm. The expectation is that procedures will be tailored to avoid or reconcile discrepancies, comply with applicable laws, and insure that information provided to consumers is accurate.
Institutions should review the guidance to make sure that their existing practices meet the expectations and/or to fill any gaps that may exist in your compliance management system.
While we’re on the topic of Deposit Operations, if you’re looking for a refresher on Deposit Operations compliance, be sure to join us for our WEBINAR on August 31, 2016. We will provide an overview of major regulatory requirements, hot button issues and the latest guidance.