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#1713200 - 06/22/12 01:29 PM Posting of Interest/Fees - Same Day vs. Next Day
FlyinHawaiian Offline
New Poster
Joined: Jul 2011
Posts: 12
Background - System migration from legacy batch processing system to realtime system.

Current As-Is process is to calculate and post accrued interest and any account fees at the end of the day via batch.

Proposed To-Be process is for interest and fees to post at the begining of the next business day.

I've identified the obvious gap in our current disclosed interest posting and the confusion this is going to cause customers looking at their prior day reports/statements, but I am wondering if I can get some more ammo to support my objection. I'm hoping to hear from some of the experts that it's standard best practice in the US for interest and fees to post the same business day. I did a quick scan of Reg DD/TISA but didn't see anything there that would support same day posting. My only thought is that for interest that posts monthly (such as our MMDA), the interest would post after the statement cycle, but I can't find anything in DD.

Amount of interest (§ 230.6(a)(2))
An institution must state the dollar amount of interest earned during the statement period, whether or not it was credited. In disclosing interest earned for the period, an institution must use the term “interest” or terminology such as: . “Interest paid,” to describe interest that has been credited; or . “Interest accrued” or “interest earned,” to indicate that interest is not yet credited


This section seems to imply that an account maintenance fee could apply to a prior period:

Fees imposed (§ 230.6(a)(3))
An institution must report any fees that are required to be disclosed and that were debited to the account during the statement period, even if assessed for an earlier period. The fees must be itemized by type and dollar amounts. When fees of the same type are imposed more than once in a statement period, an institution may itemize each fee separately or group the fees together and disclose a total dollar amount for all fees of that type. See Staff Commentary for exceptions. When fees of the same type are grouped together, the description must make clear that the dollar figure represents more than a single fee, for example, “total fees for checks written this period.”

For fees associated with the payment of overdrafts, an institution must separately identify whether the fee was for the payment of an overdraft or for returning the item unpaid, whether or not the institution promotes the payment of overdrafts (see Staff Commentary section 230.6(a)(3)-2(iv)). In addition, an institution must provide totals for fees for the payment of overdrafts and for returned items unpaid, both for the statement period and for the calendar year to date. See section 230.11(a)(1) and (2).


Not sure if there are any other applicable regs I can cite.

Thanks in advance.
Last edited by FlyinHawaiian; 06/22/12 01:42 PM.
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Operations Compliance
#1713399 - 06/22/12 05:46 PM Re: Posting of Interest/Fees - Same Day vs. Next Day FlyinHawaiian
Milby Offline
Platinum Poster
Joined: Apr 2007
Posts: 953
Tejas
I sure would love to know who/why this is proposed. Its confusing to the customers and certainly not an industry standard. It seems backwards to the trend to get even more "real time."

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#1713460 - 06/22/12 07:35 PM Re: Posting of Interest/Fees - Same Day vs. Next Day FlyinHawaiian
FlyinHawaiian Offline
New Poster
Joined: Jul 2011
Posts: 12
The To-Be process is based on the existing out-of-the-box functionality of the new system (not developed by a US vendor nor currently deployed in the US).

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