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#2091430 - 08/03/16 07:35 PM Deposit Reconciliation in our account disclosures
Red Raiders Offline
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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
rlcarey Online
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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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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
Elwood P. Dowd Offline
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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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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
rlcarey Online
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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
BrianC Online
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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
Elwood P. Dowd Offline
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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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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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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
BrianC Online
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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
JC Offline
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Oklahoma
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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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
Elwood P. Dowd Offline
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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
JC Offline
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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
rlcarey Online
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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
Elwood P. Dowd Offline
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OMG, I'm channeling my mother!

"If a peddler told you to jump off a cliff, would you do it?" blush
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#2098149 - 09/13/16 12:27 PM Re: Deposit Reconciliation in our account disclosures Red Raiders
Bankwoman1 Online
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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
Tracey, CRCM Offline
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Gorham, ME
Sounds like we are all using the same vendor-
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