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#2037386 - 09/04/15 05:30 PM Holding checking/savings statements at branch
compliancemap Offline
Joined: Apr 2012
Posts: 59
Our bank is currently in the process of an acquisition. The target bank that we are acquiring currently holds checking/savings account statements as well as coupon books in the branches for the customers to pick up (versus mailing out). For a variety of reasons, this isn't a good idea. My problem is that I am having a hard time coming up with specific regulatory reasons to provide to management to to convince them that we should not carry this practice forward in a way that would supply support for my rationale.

If any one is willing to help me with pointing me toward resources I can site that would discourage this practice (regulatory or otherwise) your help would be greatly appreciated! My previous research in the forums didn't provide me with specific resources to point to.


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Operations Compliance
#2037397 - 09/04/15 06:05 PM Re: Holding checking/savings statements at branch compliancemap
BrianC Offline
Power Poster
Joined: Nov 2004
Posts: 6,239
This is not a regulatory issue, it is a "Why place the liability risk on the Bank issue?"

Generally with these arrangements the statements need to be kept under dual control. The customer has to provide identification and sign acknowledging receipt of the statements.

A. Why take up the space in your branch for those customers who never pick up the statements.
B. Is it worth the risk on a safety and soundness audit to be written up because someone forgot to get a signature?
C. What do we do when someone accidently gives a customer the wrong statement?
D. Are you being compensated in the form of a monthly service fee for all of the hassle of managing this?
E. If the customer really doesn't want statements mailed home for whatever reason, suggest e-Statements for free or suggest they invest in a post office box.
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!

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