1. Many of our savings accounts are linked to deposit accounts to cover overdrafts. They are currently being abused and we are in the process of trying to fix the problem. My question is, due to the fact that our system transfers per item and not a lump sum, can we count it as a lump sum per day, or do I have to stick with the actual number of transfers from the savings account?

2. A customer comes in Saturday and tells half the bank that he has cash in his safe deposit box. Management wants to know if this is SAR Worthy.

Thanks!

Are you able to modify your parameters to make a lump-sum sweep each day? Most system transfers I have seen have been able to do so as a lump sum. How are your disclosures worded? Would they need to be modified too?

We are not able to modify our system to do lump sum. I will have to check on the disclosure.

1) If they are individual sweeps, you cannot lump them together.

2) Unless you feel that there is something suspicious about the customer or the source of the money, the fact that he has cash in a S/D is really not that unusual.

The Fed specifically discussed the individual vs. lump-sum transfer question, in a Staff Opinion of July 13, 1992 (FRRS Locator 2-342.22), question #2. If separate transfers are made to cover individual checks, even if those checks are presented together, each transfer is counted separately. If, however, the checks are processed in a batch and only one transfer equal to the sum of the overdrafts is made from the savings account, only one transfer is counted. Posting checks in batches is sometimes referred to as "list posting."