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#1963690 - 09/22/14 07:24 PM Safe Deposit Box
lds1958 Offline
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Joined: Oct 2006
Posts: 508
For a customer to have a Safe Deposit box do they have to have a transactional account with us also?

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Deposits and Payments
#1963692 - 09/22/14 07:26 PM Re: Safe Deposit Box lds1958
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
That's up to your bank policy.
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#1963820 - 09/23/14 12:45 PM Re: Safe Deposit Box lds1958
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
...but it's a really good idea for several reasons.
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#1965027 - 09/26/14 03:34 PM Re: Safe Deposit Box lds1958
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
We only rent boxes to account-holders but now due to high demand someone suggested that we only rent to customers with an average balance over a certain amount. I asked how this would work and was advised that we would not renew if the balance for the previous period was less that the target. While I don't see how this would work operationally (not my responsibility) I wonder if this would risk any sort of issues or violations with respect to discrimination and would like to hear opinions on this.

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#1965090 - 09/26/14 05:06 PM Re: Safe Deposit Box lds1958
rlcarey Offline
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rlcarey
Joined: Jul 2001
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Galveston, TX
You can choose to run off your customers in any way you choose.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1965118 - 09/26/14 05:50 PM Re: Safe Deposit Box lds1958
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
We would not 'run them off' in the sense that we would not close their deposit account but we would, in some way, close their SDB and I just want to make sure that this would not violate anything or open us up to any claim of discrimination, UDAAP, etc.

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#1965121 - 09/26/14 05:55 PM Re: Safe Deposit Box lds1958
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
What prohibited basis would you be discriminating against even if there were fair deposit laws.

The amount of revenue generated from safe deposit boxes is so small that why would you want to increase the maintenance costs on a product that is already in most cases a loss leader??

Forcing people to come in and get their stuff, people not coming in, drilling boxes (to find them empty), maintaining drilled inventory, trying to collect drilling fees, all from customers that most likely have been paying their box rent for years.

It's a lose/lose in my mind.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1965171 - 09/26/14 07:42 PM Re: Safe Deposit Box lds1958
CULady Offline
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Joined: Sep 2007
Posts: 496
WA
So you want to kick people off their boxes who are not behind in payments and who have possibly had them for years and years all because of a balance on a certain day?

I agree with rlcarey, lose/lose... Sounds like a PR nightmare...

We have a high demand for ours as well, but we just keep a waiting list. If you wanted to do "must have $XX balance" or must have been with ABC Bank for X years before opening new ones, I could see that, but not for the purpose of kicking anyone off.

As to your question, it might not be UDAAP on the surface, but it could end up affecting a certain protected group or two in the long run.

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#1965203 - 09/26/14 08:51 PM Re: Safe Deposit Box lds1958
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
Please don't kill the messenger. Someone in Operations got the idea and asked us (Compliance) if it would violate anything. I told them that I thought that it is a dumb idea but since it is not my call I wanted to understand the compliance issues, if any. Let's all move on and have a good weekend.

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#1965225 - 09/26/14 09:36 PM Re: Safe Deposit Box lds1958
CULady Offline
Gold Star
Joined: Sep 2007
Posts: 496
WA
Sorry devs, didn't mean YOU personally! I figured it was coming from higher up because they seem to have ALLLL the "great" ideas! wink

But I also work at a CU, so we are conditioned to think about the people and not the money! wink

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#1965261 - 09/27/14 01:54 AM Re: Safe Deposit Box lds1958
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
Well, the fact of the matter is that if you are a compliance officer, then you should be part of executive management. As such, your opinions expressed to other members of senior management should go well beyond compliance issues and regardless of whether or not an idea or proposal is compliant, an opinion that the whole idea is stupid and just downright dumb should be able to be expressed. If that is not the position you find yourself in, then I suggest you find a new organization in which to address compliance issues.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1968920 - 10/10/14 07:16 PM Re: Safe Deposit Box lds1958
kelso Offline
Member
Joined: Mar 2010
Posts: 75
Indiana
So to clarify, we are now in the process of having their bills paid from their checking or savings accounts. We have been pretty successful, except about 5 accounts will not open up a tranactional account with us. Do we have the right to make them or suggest that they close their safe deposit box? Cna we send them a letter 30 days in advance that our procedures and/or policy has changed to do so?

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#1969011 - 10/11/14 11:07 AM Re: Safe Deposit Box kelso
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Safe deposit boxes are governed by state statutes, state court decisions and, more specifically, by the terms of the lease or contract. Your sources of law will likely indicate that either the lessor or the lessee can terminate the contract at will. Read them to find out.

Regardless, this isn't like unilaterally terminating a deposit account. The renter has the keys. It will be expensive for you to access a box without them. So, don't make any threats not supported by your contracts or that you are not otherwise prepared to back up.
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