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#2195256 - 10/11/18 07:03 PM Christmas Club-Offer of AFT in lieu of Check
Likes to Comply Offline
Diamond Poster
Joined: Nov 2008
Posts: 1,060
In the mountains
Our Operations Dept would like to send an email offering Christmas Club account holders the option of an AFT into another one of their accounts with us in lieu of issuing a check.

Do the requirements of 1005.10(b) Written Authorization apply if the AFT request is for one-time only?
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Operations Compliance
#2195266 - 10/11/18 08:13 PM Re: Christmas Club-Offer of AFT in lieu of Check Likes to Comply
Likes to Comply Offline
Diamond Poster
Joined: Nov 2008
Posts: 1,060
In the mountains
For ongoing AFTs...do you allow a customer to verbally agree and document that agreement onto a AFT form?
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Always learning something new...

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#2195267 - 10/11/18 08:14 PM Re: Christmas Club-Offer of AFT in lieu of Check Likes to Comply
Susielou Offline
Gold Star
Joined: Aug 2005
Posts: 343
Midwest
We are planning on sending a letter to Christmas Club members stating that we will deposit their money into the funding account instead of receiving a check. Is there any issue to this?

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#2195277 - 10/11/18 08:55 PM Re: Christmas Club-Offer of AFT in lieu of Check Likes to Comply
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,684
Cape Cod
One or more of your customers might not like it. I haven't used a club account for decades, but if had one and had a reason I wanted a check at maturity rather than backwashing the funds to my funding account, I might not be happy. If you offer it as an option rather than present it as a fait accompli and then only accept club accounts with that feature next year, things might go more smoothly.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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