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.
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them.
Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).