Thread Options
#1566200 - 06/16/11 09:52 PM Reg D and violations!
Happy Drugs Offline
Platinum Poster
Happy Drugs
Joined: Feb 2007
Posts: 597
Central Texas
We have an option in our software to do what is called a keyboard transfer. We have had an employee that has appeared on the violation report with 7 transfers in the month of June from transferring from savings to checking. Would we consider this an on-us transaction since she works here?
_________________________
In my pill box counting my stash!

Return to Top
Deposits and Payments
#1566221 - 06/16/11 10:57 PM Re: Reg D and violations! Happy Drugs
buggs Offline
Power Poster
Joined: May 2005
Posts: 8,487
Could you explain a little more about what you mean by "our software" and "keyboard transfer?"

Are you talking about your online banking system or your core deposit system?

How does a keyboard transfer get done.

Return to Top
#1566309 - 06/17/11 01:04 PM Re: Reg D and violations! buggs
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 78,643
Galveston, TX
If this transfer was conduct by the employee outside of an on-line banking platform which all respective customers have access, then they should not be able to process transactions on their own account. I would hope your code of conduct addresses this.

Regardless, I would count them.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1566390 - 06/17/11 02:04 PM Re: Reg D and violations! rlcarey
AuditorK Offline
Platinum Poster
Joined: Feb 2003
Posts: 962
PA
Our president shows up on the Reg D excess transactions report every month because of these "keyboard transfers" via our core system.

If our customers come to the teller line and ask to transfer funds from one account to another, we use a keyboard transfer since it's easier than writing out tickets. Since the customer is doing this "in-person, in the bank", we don't count these as counted transactions in the limit of 6. Now if they telephone us and ask for a transfer, these keyboard transfers would count toward the 6.

Our president also uses this same reasoning (he is actually physically in the bank effecting the transfer) to not count this as a violation.

Whether right or wrong - I assume that's up for debate.

Return to Top
#1566395 - 06/17/11 02:07 PM Re: Reg D and violations! AuditorK
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
FWIW, the president, nor any other employee should be using the core transfer process for conducting their own transactions. So, is he doing it..or is a teller doing it for him?

The problem you face with core keyboard transactions is generally, you virtually have zero audit trail. NOt really a good thing.

IF all of these transactions are conducted at the teller line, I would agree they do not count. IF the president (or any other employee) is conducting his own transfers. it would count and the procedures need to be changed to not allow this to continue. You are setting yourself up for employee misconduct.
Last edited by RR Joker; 06/17/11 02:09 PM.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#1566397 - 06/17/11 02:21 PM Re: Reg D and violations! RR Joker
buggs Offline
Power Poster
Joined: May 2005
Posts: 8,487
What they said!

1. "Keyboard transactions" to avoid the chore of writing a check are a very bad idea unless you have appropriate controls to prevent and/or detect fraud.

2. Although an argument could be made that the transfers should not be counted against Regulation D limits for savings deposits, I would strongly recommend counting them to help discourage the activity and to alert management when the transactions appear to be excessive from a fraud perspective.

Return to Top
#1566422 - 06/17/11 02:50 PM Re: Reg D and violations! buggs
waldensouth Offline
Power Poster
waldensouth
Joined: Nov 2001
Posts: 7,979
FINALLY ABOVE the gnat line
We set up a different transaction code for those transfers/withdrawals performed at the teller line for the customer. That made monitoring for excessive transactions much less complicated.
_________________________
"Once you learn to read, you will be forever free."

- Frederick Douglass




My Opinion Only.

Return to Top
#1566500 - 06/17/11 03:53 PM Re: Reg D and violations! waldensouth
AuditorK Offline
Platinum Poster
Joined: Feb 2003
Posts: 962
PA
Oh believe me, I've tried to convince management and the president that employees should not be processing their own transactions, whether via keyboard transfer or otherwise. I haven't been successful, despite showing all the dangers.

At least our keyboard transfers do indicate the user who initiated the transfers.

Return to Top
#1566624 - 06/17/11 06:12 PM Re: Reg D and violations! AuditorK
buggs Offline
Power Poster
Joined: May 2005
Posts: 8,487
Sometimes it takes a whack with a two-by-four to wake people up. I hope that isn't what does it for your bank. frown

Return to Top
#1566901 - 06/20/11 02:18 PM Re: Reg D and violations! buggs
A_G Offline
10K Club
Joined: Jul 2004
Posts: 18,957
Have you looked at your employee handbook or code of conduct yet?

I would think (hope!) something about this is addressed there.
_________________________
With the lights out, it's less dangerous.

Return to Top

Moderator:  John Burnett