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Question & Answer
Question: Can we have different hold policies in different branch locations?
Answer: Yes, you can. But the policies must each be clearly disclosed and explained. You want to be sure that your customer knows (or can easily find out) the difference in hold policies by taking their transaction to a different branch. You have two choices about disclosures. First, you can have two sets of disclosures and signs for each hold area. As an easier but perhaps less competitive alternative, you can provide all customers with uniform disclosures that show the longer hold periods. The important aspect of a hold notice is to be sure that the customer knows how long the hold may be. A shorter one is always nice, but not necessary to disclose.
Copyright © 1999 Compliance Action. Originally appeared in Compliance Action, Vol. 4, No. 16, 12/99
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