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#2235539 - 04/23/20 06:48 PM No signature required
Jenny Roberts Offline
100 Club
Joined: Feb 2014
Posts: 162
Tennessee
We are wondering if we can eliminate signatures on transaction tickets for customers when they perform transactions that do not involve getting cash back.

For example, a customer comes in to the bank and wants to transfer money from his saving to his checking without getting cash back. We normally have them go ahead and sign the withdrawal ticket since they are present but we just perform the transaction via our Core online option and eliminate manual tickets?

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#2235547 - 04/23/20 07:22 PM Re: No signature required Jenny Roberts
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,275
Illinois
As with any business decision, you have to consider the risks of eliminating a signature for an in person transaction.

1. My wife has an individual savings account and we have a joint checking account. You permit a withdrawal without a signature to transfer funds to the joint checking account. I spend all the money. My wife later says that my mistress made the transfer request so I could steal the money during our divorce. What record will we have to prove that my wife was the person that authorized the transfer?

2. At Top Gun this year I shared an enforcement action against a former bank employee that made transfers without customer signatures into a dormant account which they used to steal funds from the customer and ultimately the bank. What controls do we have in place to mitigate risks of insider fraud?

3. What does our current account agreement say about requirements for a customer requesting withdrawals? Our processes should align with what we've agreed is required.

Your question is not a compliance question. It's not a matter of can or can't. It's a legal question and a safety and soundness question. Will your institution accept the risk of eliminating this control and are other processes mitigate that risk? What are the financial and legal risks that you face if this change is made? I suggest discussing your options with legal counsel.
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