We might call the customer instead of sending a letter. They do get system generated notices when they exceed the limit monthly. If they are a frequent violator, though, we might call or send a letter. We just document what we did and when.

Our procedures require that we keep a copy of the letters. The personal banking manager at each branch is responsible for monitoring the excessive transactions for thier branch with a copy of the monthly report noting their contact forwarded to me. I require the PB manager to call the customer when the 2nd letter is mailed out to discuss the situation with the customer and see if there is some way to assist the customer with ways to access to their funds in the MMDA or Savgs within the restrictions. Often it only means talking out timing on transfers etc. Seems to work for us, this has become a managable issue now and generally the letters and calls are well received by the customers.

Copy of letter not maintained. Spreadsheet listing is maintained. It includes customer name,acct number, date notified, times notified and other actions taken.

We keep an electronic copy only.

I have now voted but want to provide some follow up based on a recent fdic examination. The examiners are requested a listing of accounts that have exceeded the applicable transaction limit on savings and money market accounts. If you can not document that the customer was notified of the violation, then they are citing this as a violation.

At my ex-bank, the letters were generated automatically based on occurance - first, second and third. The first letter was sent to the branch officer, who had the option of sending it or contacting the client by phone, or both. The second letter was sent to the client directly, and the third letter was sent informing the client that the account had been converted to a non-interest-bearing account. There was a report generated tracking each account and the letters sent, and any exceptions were documented and retained. Our regulators did not expect to see copies of each letter sent, as the letters were the same based on the severity of the violation. What they did want to see were the reports, our written procedures and any documentation allowing exceptions.
BC

I like complianceman's response. It is really documentation on what you did. If you use a standard letter knowing that it was sent is fine. If you call, enter that as an option and perhaps notes of the discussion.

Bear Collector, what "exceptions" were allowed and accepted by examiners? The only gray area I saw as a potential exception was the check written in Jan. that didn't clear until May when other items did, making that an excessive month through no fault of the customer.