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#2091430 - 08/03/16 07:35 PM
Deposit Reconciliation in our account disclosures
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Diamond Poster
Joined: May 2013
Posts: 1,069
Compliance Land
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We reconcile all of our deposits and do not have a minimum amount of variance that we won't research. Our deposit software provider has contacted us and said we have the option of including a blurb about our deposit reconciliation practices in our new account disclosures. This isn't required, is it?
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#2091437 - 08/03/16 07:54 PM
Re: Deposit Reconciliation in our account disclosures
Red Raiders
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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No. They are trying to sell forms.
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#2091440 - 08/03/16 07:59 PM
Re: Deposit Reconciliation in our account disclosures
Red Raiders
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Diamond Poster
Joined: May 2013
Posts: 1,069
Compliance Land
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I thought so but just wanted to make sure I wasn't missing anything. Thanks!
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#2091492 - 08/04/16 10:49 AM
Re: Deposit Reconciliation in our account disclosures
Red Raiders
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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Profoundly bad idea.
Never take advice from a forms vendor.
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#2091805 - 08/05/16 02:08 PM
Re: Deposit Reconciliation in our account disclosures
Red Raiders
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Diamond Poster
Joined: May 2013
Posts: 1,069
Compliance Land
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I got a little bit more information on this. It turns out they are making these changes regardless and also changing several other items on the terms and conditions that I deem to be minor. I think what they are trying to do it get us to buy the newly revised terms and conditions to send to all of our customers so that we can keep some "warranty of compliance".
Is there anything wrong with not spending thousands of dollars in printing and postage and just give the newly revised disclosures to new customers?
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#2091815 - 08/05/16 02:20 PM
Re: Deposit Reconciliation in our account disclosures
Red Raiders
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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Yes. Because when you get sued, how are you going to know and prove what contract you have with which customers??
This is the problem with form vendors, they continually update things for really no reason which costs the banks thousands.
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#2091823 - 08/05/16 02:25 PM
Re: Deposit Reconciliation in our account disclosures
Red Raiders
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Power Poster
Joined: Nov 2004
Posts: 6,694
Illinois
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Since your disclosures are a deposit contract, not sending revised contracts to existing customers would result in your institution operating with two separate contracts. This could present a challenge should any legal proceedings arise between you and a customer. There is a Related thread probably regarding the same forms vendor. I will give you the same advise that Randy and I gave a fellow BOLer. You can either trust your forms vendor's attorneys and pay up or you can have your own counsel review the proposed changes and determine if they are actually necessary.
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#2091824 - 08/05/16 02:26 PM
Re: Deposit Reconciliation in our account disclosures
Red Raiders
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Joined: Aug 2001
Posts: 21,939
Next to Harvey
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It's a scam. Citizens Bank did not get dinged because they did not address the issue in their contract. They did. The contractual wording was fine. They got dinged because they did something other than what their contract said they would do. Ain't no guarantee gonna cover that!
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#2091831 - 08/05/16 02:36 PM
Re: Deposit Reconciliation in our account disclosures
Red Raiders
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Diamond Poster
Joined: May 2013
Posts: 1,069
Compliance Land
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Brian, I am pretty sure, knows which vendor we are dealing with. Does anyone know if we can tell them that we don't want the changes made at all? They are saying that they are going to automatically update our software that is tied in to our core for account opening but I didn't know if we had the ability to say "no!".
I am fairly new to this bank and I think in the past our lawyer had said just make the changes going forward but I haven't heard that firsthand yet.
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#2091833 - 08/05/16 02:40 PM
Re: Deposit Reconciliation in our account disclosures
Red Raiders
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Diamond Poster
Joined: May 2013
Posts: 1,069
Compliance Land
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Ken,
I definitely agree that it is BS but not sure the best route to go!
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#2091837 - 08/05/16 02:47 PM
Re: Deposit Reconciliation in our account disclosures
Red Raiders
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Power Poster
Joined: Nov 2004
Posts: 6,694
Illinois
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They're your disclosures, you can tell the vendor anything you want. The pressure that your vendor is trying to apply to you is that they will not "warranty" your disclosures if you don't make every last change that want to make you pay for. They are counting on the fact that most compliance professionals are very risk averse and will spend the money similar to buying an insurance policy.
Certainly check to see if your institution has signed a contract that obligates you to purchase current and future changes, but I'm guessing it is more of a case by case basis.
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#2093397 - 08/16/16 01:24 PM
Re: Deposit Reconciliation in our account disclosures
Red Raiders
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100 Club
Joined: Jan 2014
Posts: 147
Oklahoma
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The interagency guidance expectation is that FI's provide accurate information to customers about deposit reconciliation practices. Why wouldn't you want to add that information to your new account opening disclosures?
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#2093402 - 08/16/16 01:35 PM
Re: Deposit Reconciliation in our account disclosures
JC
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Diamond Poster
Joined: May 2013
Posts: 1,069
Compliance Land
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Our practices have not changed. We do not do anything like credit a customer's account $100 when they deposit $110. If there is a discrepancy, we research it and credit the correct amount. I am not crazy about spending $25,000 to tell customers that they will be credited the amount they deposited.
Last edited by Red Raiders; 08/16/16 01:36 PM. Reason: grammar
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#2093423 - 08/16/16 02:36 PM
Re: Deposit Reconciliation in our account disclosures
Red Raiders
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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Yours is the perfect example of how this would be a waste of money.
Banks for which this is an infinitesimally low level of risk are those that "proof" the deposit at the window. Think about it; any mistake should be caught before the items are even processed. If you don't have an outage it's even more unlikely that you will come up with a "solution" that is stupid.
Your vendor is offering a solution in search of a problem.
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#2097709 - 09/09/16 04:47 PM
Re: Deposit Reconciliation in our account disclosures
Red Raiders
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100 Club
Joined: Jan 2014
Posts: 147
Oklahoma
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Does anyone have a policy in the works? What do your T's& C's say about how you are handling variances?
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#2097710 - 09/09/16 04:56 PM
Re: Deposit Reconciliation in our account disclosures
Red Raiders
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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The policy would be to fix them all, then you don't need anything in your T&C.
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#2098146 - 09/13/16 11:36 AM
Re: Deposit Reconciliation in our account disclosures
rlcarey
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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OMG, I'm channeling my mother! "If a peddler told you to jump off a cliff, would you do it?"
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#2098149 - 09/13/16 12:27 PM
Re: Deposit Reconciliation in our account disclosures
Red Raiders
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Diamond Poster
Joined: Dec 2015
Posts: 1,046
Midwest
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We are currently updating our T&C's and I'm sure we are using the same forms vendor. We chose not to add the section you are speaking about because like you, we correct any discrepancies. However my financial institution chose to make the other updates they were making. We were also making some updates of our own so either way it was going to happen. But in regards to the section on discrepancies - as I said above - we chose not to add it to our T&C's.
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#2098512 - 09/14/16 07:14 PM
Re: Deposit Reconciliation in our account disclosures
Red Raiders
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Platinum Poster
Joined: Jul 2015
Posts: 542
Gorham, ME
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Sounds like we are all using the same vendor-
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