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#1985627 - 12/30/14 07:01 PM Closing account after SAR filing
Lilly C Offline
100 Club
Lilly C
Joined: Dec 2004
Posts: 209
Sunny Florida
We decided to close out an account relationship and notify the customer the same day of the SAR decision was made. This was based on suspicious activity. Our terms say we can close an account and give reasonable time to notify the customer or if suspicioius activity is detected we can close first and notify later.
It's a difficult conversation to have with the customer without mentioning suspicious activity or sar filings.
How are banks handling this conversation?
Other than keep saying "it was a bank decision".
Last edited by Florida Babe; 12/30/14 07:02 PM.
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#1985642 - 12/30/14 07:30 PM Re: Closing account after SAR filing Lilly C
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
There have been a number of threads on this, so many in fact that Mary Beth did a presentation at Top Gun a couple years ago entitled, "Dear Customer, You're Toast." Even she did not come up with a magic phrase or the generic letter that bankers fantasize about that is guaranteed to keep the customer from being mean to them.

To summarize prior discussions:

* Look at the signature card the customer signed for language that gives you the right to unilaterally close an account. Quote it in the letter.
* Give the customer adequate notice of the closing; i.e. time to let outstanding checks clear. There is no specific time frame, but, in my opinion 10 to 14 days is adequate. (If the customer deposits large volumes of checks or frequently has returns of deposited items it simply is not in your best interest to pull this trigger too quickly. On the other hand, if the customer is kiting, you probably cannot pull it quickly enough.)
* Say that the only deposits you will accept after the date of your letter are those necessary to cover checks outstanding on the date of your notice to the customer and ask the customer to provide you a list of those specific items
* Note that all checks deposited will be subject to the maximum hold allowed by law.
* As for "the reason:" Because the contract says you can or it was a bank decision work just fine.

The comment that was most common in prior threads is the more you say, the more reason(s) you offer, the worse it's going to get. Why bother? The customer can like it or they can lump it, but the decision isn't going to change. There is no "silver bullet" wording that will eliminate the conversation. So, the best conversation is a short conversation.

Keep in mind, the customer may well know exactly why the account is being closed and you will never hear from them.

P.S. I personally have zero tolerance for kiting. If that's the reason for account closure in my bank, my letter would say that only cash deposits would be accepted from that point forward, the timeframe in which the account would be closed would be 5 days, and the reason would be "consistently drawing on uncollected funds."
Last edited by Ken_Pegasus; 02/04/16 11:27 AM. Reason: Reworded.
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#1985644 - 12/30/14 07:37 PM Re: Closing account after SAR filing Lilly C
Lilly C Offline
100 Club
Lilly C
Joined: Dec 2004
Posts: 209
Sunny Florida
thanks, Ken. You are the best!! I will certainly reach out to Mary Beth to see if she stills offers some webinar on this.
Love the "Dear customer you are Toast" title!!!
Happy New Year,Ken

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