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#1526453 - 03/24/11 03:35 PM opening deposit- TISA requirement
sunshinebanker Offline
100 Club
Joined: Mar 2006
Posts: 233
Our bank opens an account for a customer to receive their federal tax return. No other deposits or w/d other then the pymt out of the tax return are allowed. There is no mention in the TISA disclosure of the minimum opening deposit amount; in our case it would be whatever the tax refund is.Do we need a sentence to say that? something like, "the minimum to open this account is your tax return amount?" the "accounts" are in our ledger for virtually 2-3 days and then refund is paid out.

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Operations Compliance
#1526900 - 03/25/11 12:37 AM Re: opening deposit- TISA requirement sunshinebanker
Deputy Dawn Offline
Gold Star
Deputy Dawn
Joined: Feb 2007
Posts: 485
Why do you do this? Are you charging a fee for the account?

I'm curious.

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#1527184 - 03/25/11 05:40 PM Re: opening deposit- TISA requirement Deputy Dawn
BrendaC Offline
Power Poster
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
With all of the BSA hoops we have to jump through, I'm curious as well. Hard to imagine the risk/benefit is really there. I guess I'm scarred, all I see are discrepancy documentation and retention issues looming on a rapidly growing tracking report.
Life without Jesus is like an unsharpened pencil - it has no point.

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#1527829 - 03/28/11 08:12 PM Re: opening deposit- TISA requirement BrendaC
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
TISA only requires mention of an opening deposit if there is one and if it is greater than the balance required (again, if there is one) to receive the advertised or disclosed APY (once again, if there is one). Virtually every disclosure in TISA is on an "as applicable" basis.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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