Re-evaluate Your “Cost of Doing Business” Practices
Some financial institutions do NOT research or resolve EVERY deposit discrepancy and regard it as “a cost of doing business”. If that is your institution, then you may want to RE-EVALUATE your position.
Research and resolution of deposit errors can be more costly and time consuming than accepting minor discrepancies. However, The Consumer Financial Protection Bureau (CFPB) and four federal financial regulatory agencies issued guidance on how to handle consumer deposit discrepancies.
The interagency guidance states that financial institutions should AVOID or RECONCILE, or RESOLVE discrepancies between the amounts they credit to a consumer’s account and how much was actually deposited. The guidance calls on financial institutions to adopt policies that treat consumers fairly when they make deposits and do not violate law including prohibitions against unfair, deceptive, and abusive practices.
On August 12, 2015, the CFPB, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation took action against Citizens Bank, N.A., for failing to credit consumers the full amounts of their deposited funds. The CFPB’s consent order requires the bank to provide approximately $11 million in refunds to consumers and pay a $7.5 million penalty for the violations.
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