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#2227940 - 12/23/19 09:05 PM Customer with Excessive WDs
TeamComply Offline
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Joined: Aug 2016
Posts: 393
Bank monitors its savings and MMDA accounts for excessive withdrawal activity. Bank identified a savings customer with excessive withdrawal activity, and sent out notice letters with three occurrences, and with the third, notified the customer the account would be re-classified or closed, but could not remain as a savings account. Customer closes account. Customer then several months later, appears at another branch to open a new savings account. Should this be allowed? Or should bank maintain a list of individuals who have previously violated the excessive withdrawal limits at the bank, and therefore aren't allowed to maintain this type of account with the bank ever? How do most banks handle this? Can a customer wait 6months, a year, etc. and then open a savings or MMDA account again, if they previously had such an account closed/re-classified by bank, as a result of excessive withdrawal activity?

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#2227944 - 12/23/19 09:12 PM Re: Customer with Excessive WDs TeamComply
burkemi Offline
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Joined: Nov 2013
Posts: 465
The regulation is mute about opening another account. The 3 strikes rule is even just a rule established by industry practice and not mentioned specifically in the reg.

To more directly answer your question - yes, by regulation (or lack of acknowledgement in the reg) your customer can open a new account. What your bank will/will not allow is up to management.
I reject your reality and replace it with my own.

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#2227946 - 12/23/19 09:13 PM Re: Customer with Excessive WDs TeamComply
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,333
Cape Cod
Most banks set up a rule they can enforce and follow it. Some will allow an errant customer a second chance; some won't. Some will allow it and don't watch who's coming back time after time. Those banks could have trouble with examiners.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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