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#1603609 - 09/14/11 06:30 PM Savings Account Excess Transaction Notice
Loraine Offline
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Is there anywhere that states these notices may be sent electronically?

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#1603848 - 09/15/11 12:04 AM Re: Savings Account Excess Transaction Notice Loraine
rlcarey Online
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rlcarey
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I doubt that this is addressed in State law. There is no Federal requirement to send any notices. You just have to have procedures to stop this from happening and most banks use a series of letters to warn the customers.
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#1604143 - 09/15/11 05:17 PM Re: Savings Account Excess Transaction Notice rlcarey
Loraine Offline
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But, can those series of letters have to be written or can they be electronic?

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#1605125 - 09/16/11 09:44 PM Re: Savings Account Excess Transaction Notice Loraine
Comply 101 Offline
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Examiners will want to see that you are attempting to correct your customer's behaviour. They might ask you to prove that the customer received your electronic transmission. Paper or electronic, if the customer's behaviour continues, they won't like it. Any attempt will work IMO, as long as it stops the customer from violating the reg in the future.
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#1605158 - 09/16/11 11:08 PM Re: Savings Account Excess Transaction Notice Comply 101
rlcarey Online
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rlcarey
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"Examiners will want to see that you are attempting to correct your customer's behaviour."

Why? There are no notice requirements under the regulation. You can a have a three strikes rule and never once communicate to the customer until you close their account. Not very good customer service, but well within the regulation.
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#1605169 - 09/17/11 01:01 AM Re: Savings Account Excess Transaction Notice rlcarey
Kathleen O. Blanchard Offline

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The majority of banks have always, for many years, interpreted the footnotes to mean you are expected to notify the customer when they exceed the limit and give them an opportunity to stop the behavior. Then after the warnings, you take action.

In today's climate I would not want to take action without warning.

From the definition of savings account:

4 In order to ensure that no more than the permitted number of withdrawals or transfers are made, for an account to come within the definition of “savings deposit,” a depository institution must either:

(a) Prevent withdrawals or transfers of funds from this account that are in excess of the limits established by paragraph (d)(2) of this section, or

(b) Adopt procedures to monitor those transfers on an ex post basis and contact customers who exceed the established limits on more than occasional basis. For customers who continue to violate those limits after they have been contacted by the depository institution, the depository institution must either close the account and place the funds in another account that the depositor is eligible to maintain or take away the transfer and draft capacities of the account. An account that authorizes withdrawals or transfers in excess of the permitted number is a transaction account regardless of whether the authorized number of transactions is actually made. For accounts described in paragraph (d)(2) of this section, the institution at its option may use, on a consistent basis, either the date on the check, draft, or similar item, or the date the item is paid in applying the limits imposed by that section.
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#1605204 - 09/18/11 12:15 AM Re: Savings Account Excess Transaction Notice Kathleen O. Blanchard
rlcarey Online
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rlcarey
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Galveston, TX
Thanks - Kathleen - forgot that important footnote.
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#1605212 - 09/18/11 10:54 PM Re: Savings Account Excess Transaction Notice rlcarey
Kathleen O. Blanchard Offline

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I've always loved regulation by footnote.
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