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#2026107 - 07/08/15 10:25 PM Access Device Being Sent to the Institution
Lil'Belle Offline
100 Club
Lil'Belle
Joined: Dec 2006
Posts: 193
Texas, United States
Hi. I hope someone can please direct me. I looked under Reg E but can not locate the following...
When our new accounts department orders an access device for a customer, they are having it mailed to the FI. I want to say that I remember having a compliance exam many moons ago and I was asked by the examiner: "Access devices are being mailed to the customers, correct?"
There is a liability to the bank when the access device is mailed directly to the FI.

Can someone direct me to where I could be wrong about the device mailing?

Thank you so much!!!
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Chiquita pero picosa.

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#2026111 - 07/08/15 10:44 PM Re: Access Device Being Sent to the Institution Lil'Belle
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
It is not a regulatory issue per se, it is a control issue. What happens to the devices when they get the branch, are they maintained under strict dual control, what keeps a branch employee from ordering a device on an inactive account and draining it. It is just not a good process from a security standpoint. Why would they not be mailed directly to the customer??
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#2026143 - 07/09/15 01:12 PM Re: Access Device Being Sent to the Institution Lil'Belle
Lil'Belle Offline
100 Club
Lil'Belle
Joined: Dec 2006
Posts: 193
Texas, United States
Very good points, definitely eye opening. Thank you for that and thank you for your reply.
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