Not For Sissies
It was Bette Davis who first said that old age is no place for sissies. Well - let me tell you, neither is being a banker for cowards or sissies these days!
Let's look at what is coming at us through a different route. If you were to talk to a banker that retired 15 to 20 years ago, he or she would not be able to translate this sentence.
"I filed the CTR and the SAR according to the BSA, the PAT Act, and the CIP, but we still got written up for our CRA problems and a couple of RFPA errors." *
Betcha' you read it ok, didn't you? For the sake of the new-hires reading this, the sentence is translated below. Now, try this one.
"I ordered the IRD which showed the LAR very plainly, having been done with a COF in accordance with the CTA."
Stumped? It will all be as clear to you shortly as CTR and SAR were in the first sentence. What I said was, " I ordered the Image Replacement Document which showed the Legal Amount Recognition very plainly, having been done with a Common Output Format in accordance with the Check Truncation Act."
With all the changes in processing coming at us in order to comply and take advantage of the Check 21 Act, the one that will be the most troublesome to the folks reading this newsletter is where the rubber hits the road - which is to say, when the results of Check 21 are felt by your customer or member. After you have handed out all your disclosures, put on signs in the lobby, hung notices behind your desk on the wall, and broadcast in any way possible -none of which was paid the least attention to, let alone read - your customers or members will come in to you after receiving their first statement with IRDs in them and ask you, "What the heck are these things I'm getting instead of the checks I wrote? They aren't even the same size as my checks! Where's my original?!"
When banks first started imaging checks, most gave customers a choice - want them or not. Many opted to continue receiving their checks. Now, the choice is gone, because you won't get many of the checks your depositors write back through the work. They will have been imaged by the depositary bank. All you'll have is images, and all you'll be able to supply will be the IRD (Image Replacement Document - remember?)
Your customer service and marketing people should already be starting to put a spin on this by supplying you with phrases concerning patriotism (reducing our vulnerability to the effects of terrorism), efficiency, and better protection against fraud and identity theft. Can you handle this in addition to all the rest of the "stuff" you're now handling? Of course you can. You're no sissy!
* "I filed the Currency Transaction Report and the Suspicious Activity Report according to the Bank Secrecy Act, the Patriot Act, and the Customer Identification Program, but we still got written up for our Community Reinvestment Act problems and a couple of Right to Financial Privacy Act errors."
Copyright © 2003 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 13, No. 8, 11/03
First published on 11/01/2003