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#1171433 - 04/28/09 05:32 PM Debit Descriptions for Business Accounts
Anonymous
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Are we required to provide clear descriptions for debit memos on a business checking account statement?

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#1171470 - 04/28/09 05:57 PM Re: Debit Descriptions for Business Accounts Anonymous
Al Miller Offline
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Al Miller
Joined: Oct 2000
Posts: 2,416
Pleasanton CA USA
Of course not. You should make them obscure enough so that every business customer will call every day and you can justify your call center. grin

Do you mean required by regulation? no

Do you mean required by good business sense? yes


Al
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Al Miller, CRCM
Opinions expressed are my own and not necessarily shared by my employer.

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#1171487 - 04/28/09 06:03 PM Re: Debit Descriptions for Business Accounts Al Miller
Anonymous
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Yes, I meant by regulation.

I agree with you but whenever I have a suggestion to our Dep Ops personnel they usually ask "Is it required by a regulation?"

Would you consider it a best practice?

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#1171542 - 04/28/09 06:32 PM Re: Debit Descriptions for Business Accounts Anonymous
Al Miller Offline
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Al Miller
Joined: Oct 2000
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Pleasanton CA USA
Not by regulation, but they need to understand that nothing that is now required by regulation was always required by regulation.

We are blessed with Reg CC because banks unreasonably delayed availability to the point that congress "fixed" it. Congressional representatives do not dream this stuff up, but react to constituents.

We are blessed with Reg DD because banks hit consumers with hidden fees and were not up-front about such things as interest computation methods and what fees were for.

I think there are another dozen or so regulations that followed this pattern.

So, my response to the Dep Ops folk would be "not yet. But this is the kind of thinking that gets us regulations."

Al
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Al Miller, CRCM
Opinions expressed are my own and not necessarily shared by my employer.

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#1171554 - 04/28/09 06:36 PM Re: Debit Descriptions for Business Accounts Al Miller
BrendaC Offline
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BrendaC
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Sweet Home AL
If a copy of the debit memo was mailed to the customer at the time of the transaction, I could make a case that a complete description on the statement may not be necessary. If not, common sense dictates that you tell the customer the nature of the debit transaction.
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#1171633 - 04/28/09 07:10 PM Re: Debit Descriptions for Business Accounts BrendaC
John Burnett Offline
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John Burnett
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Cape Cod
You might suggest to the operations types (I know, I was one of them at the same time I "did" compliance) that it's a he** of a lot less trouble and less expensive to spell out on the memo (I am not advocating providing detailed statement descriptions for business debits) exactly what a charge is for than it is to research it after the fact.
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