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November 19
How to Conduct an Interrogation
Dana Turner

November 19
Blocking Internet Gambling -- Are You Ready?
John Burnett

November 20
Understanding Letters of Credit
Adam LaBoda

December 2
Auditing for the "Orphan" Compliance Regulations
Patricia Cashman

December 8
Robbery Suppression & Apprehension -- The SAFECATCH Strategy
Dana Turner

December 10
RESPA - Completing the New Good Faith Estimate
Mary Beth Guard and
Jack Holzknecht

December 16
RDC Risk Management and FFIEC Compliance: It is harder than you think!
Paul Carrubba and
Dan Fisher

December 18
RESPA - Completing the New HUD-1/1A
Mary Beth Guard and
Jack Holzknecht



Topic Options
#1281015 - 11/04/09 04:36 PM Regulation CC - DepositPro
Doug Hendrickson Online
Junior Member

Registered: 10/01/09
Posts: 49
Loc: NE New Mexico
I'm interested in how other banks with a "next day availability - use statutory list" in DepositPro are handling the changes to the check processing centers. Specifically, our disclosure lists the routing numbers of the local checks from the 'old' Denver processing center. I'd like to either change it to all of the routing centers now being processed in Cleveland, or delete the reference to the routing numbers and have them check with a teller until such time as all non-local checks are eliminated and DepositPro changes the whole disclosure.
_________________________
Players win games, teams win championships. -- Bill Taylor

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#1281102 - 11/04/09 05:16 PM Re: Regulation CC - DepositPro [Re: Doug Hendrickson]
rlcarey Offline
Compliance is my life

Registered: 07/16/01
Posts: 23861
Loc: Galveston, TX
What is "next day availability - use statutory list" ??

Are you a case-by-case bank?
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The opinions expressed are my own, take them or leave them.

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#1281137 - 11/04/09 05:39 PM Re: Regulation CC - DepositPro [Re: rlcarey]
Doug Hendrickson Online
Junior Member

Registered: 10/01/09
Posts: 49
Loc: NE New Mexico
Our posted funds availability policy is to "allow withdrawal of funds on the 1st business day after we receive the deposit; however in some cases we may delay the availability beyond the first business day."

The funds availability policy disclosure generated by DepositPor states that "Our policy is to delay the availability of funds from your cash and check deposits. During the delay you may not withdraw....". It then goes on to define how to determine the availability of the deposit, defines local and non-local checks and the exception holds.

In practice we use both case-by-case and exception holds.
_________________________
Players win games, teams win championships. -- Bill Taylor

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#1281367 - 11/05/09 09:37 AM Re: Regulation CC - DepositPro [Re: Doug Hendrickson]
John Burnett Online

Compliance is my life

Registered: 10/27/00
Posts: 18557
Loc: Cape Cod
Your left hand (the posted policy) doesn't appear to know what your right hand (the DepositPro disclosure) is doing. They are inconsistent. Your first step is to figure out what your policy really is; the second is to figure out what your actual practice is. The third step is to make sure your policy and practice are consistent.

Then, get your published policy and disclosures in sync with your actual policy and practices.

If you are, in fact, a next-day availability bank, you should not be using the DepositPro disclosure you have quoted, and you should not be concerned with including lists of routing numbers in your disclosures.

One can only wonder how long this diconnect has been going on.


Edited by John Burnett (11/05/09 09:41 AM)
_________________________
"I guess I should warn you, if I turn out to be particularly clear, you've probably misunderstood what I've said." -- Alan Greenspan

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#1281531 - 11/05/09 11:21 AM Re: Regulation CC - DepositPro [Re: John Burnett]
Doug Hendrickson Online
Junior Member

Registered: 10/01/09
Posts: 49
Loc: NE New Mexico
Well, I know it's been going on since before I got here on September 1st of this year. When I read the posted disclosure and then compared it to the DepositPro wording it just didn't jive.
_________________________
Players win games, teams win championships. -- Bill Taylor

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#1283179 - 11/07/09 11:51 PM Re: Regulation CC - DepositPro [Re: Doug Hendrickson]
cbinder63 Online
Platinum Poster

Registered: 12/27/01
Posts: 507
Loc: Colorado
Appears to be a setup or parameter issue within DepositPro.
_________________________
Opinions expressed are my own.

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