I am currently revising my institution's check handling policy. I desire input on how other institutions handle the deposit receipt when a non-customer makes a deposit for a customer. Our system is on-line real- time so our deposit receipt lists the amount of the deposit, the account number, and the current balance in the account. I am in favor placing the receipt in a sealed envelope with the customer's name on it so the person making the deposit may deliver the receipt to the customer. This would provide some level of confidentiality, and there would be evidence the envelope was opened. We could, of course, mail the receipt to the customer, however, many people want a receipt at the time of the transaction for proof the transaction was made. Some members of management feel we should be able to hand the deposit receipt to the person making the deposit on the customer's behalf because the customer has obviously given the non-customer the information needed to make the transaction. I would like to know how other institutions are handling this situation. Thanks for your help!

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SteveMc

Interesting question. Here are my first thoughts. If John Doe comes in and makes a deposit to jane Doe's account and he knows the account number, I should be able to give him a receipt. The receipt could have the date, amount of deposit and account # without fear that I gave him anything that he didn't already know. If John Doe makes a deposit to Jane Doe's account but doesn't know the account #, I don't think the receipt should have the account # on it. In both cases, I don't think the balance of the account should be listed.

If I called your bank and asked them if you had an account there they would probably say "We do not provide that type of information about our customers". Now if I somehow got your account number and you allowed me to make a deposit into their account, you have just confirmed that I bank there. Haven't you just violated the privacy of that customer? This is one issue of the new privacy regs that could be a loophole for scam artists.

Good point, but did you give out any information that they didn't already know? Dean, you said the customer already had my account #, and they came to your bank to make the deposit (so they must know that I bank there).

I can give a reciept (as I described in the first posting) that only gives back what they gave me. This is not a violation of privacy and is exempted under section ___.14(b)(2) which basically says that is is appropriate or an accepable method to carry out a transaqction.

Our receipts list the account number, date of deposit and amount of deposit but do not list the balance information. You should check with your systems people to see if a change can be made on the information printed out.

If a con artist had my account number and wanted to make a deposit, he/she could go ahead and do that, but would not walk away with any more information than he/she walked in with.

If a customer wants the balance in the account, the teller can print a balance information slip, but this is only done if the person is on the account.

Also, if the non-account holder is making a deposit, no "cash-back" is allowed because of the split deposit scam.

Our teller machines allow us to print receipts and validate deposit tickets seperately. Receipts include the date, account number, amount of deposit and the account balance. The deposit ticket validation has the date and amount of deposit and account number, but no balance info. If, for example, a business has sent an employee to make the deposit, the teller will validate the deposit slip instead of the receipt, so that the balance info is on the deposit ticket and the receipt is printed with only the date and amount of deposit.

When a non customer comes in to make a deposit to a personal or business account and doesn't have the account number, we mail the receipt to the customer. We don't give the non customer any info or receipt.

Privacy statement indicates that "we do not release non public information". I know that the person presenting the deposit may know the account number. However, he may not know that my account is "extremely large" or perhaps "extremely small". My point is, if I have a friend deposit cash money into my account because I have just had surgery, I don't necessarily want that friend to know that my account has a million dollars in it, just as I wouldn't want that friend to know that even with the deposit of $700.00, my account balance is still only $200.00.

This situation happened to us recently. We simply explained that because of a recent change in banking policies, we would place the receipt in the mail that evening. The person making the deposit didn't like the idea, however, the owner of the account understood.

There is a legal aspect here, in that there are terms specified on the signature card, or account agreement, that limit transactions on the account to just the bank and the signers on the account.

What if a person owed your customer $10,000 and that person told your customer that they were only going to pay back $5,000. The customer says no, going to sue. The person then comes into the bank and deposits a check in the amount of $5,000 with a qualified endorsement that says "Cashing this check is acknowledgement of all debts to John Smith as paid in full".

The deposit is accepted, and the person has a cancelled check that says paid in full.

Do you think your customer will appreciate your courtesy. No, you will be added to the law suit, and will in all probability take the loss.

This can just as easily be a scam between the person and your customer.

It seems that the critical concern here, regardless of what procedures you have in place to handle the receipt, is whether your teller realizes the person making the deposit isn't the owner of the account. This may be possible in a "small town" environment, but highly questionable in a busy branch with lots of teller turnover.

Also of concern (although not necessarily for GLB privacy purposes) -- what about balances printing on receipts for business account deposits that are brought in by a runner or clerk from the business? We have some businesses that (understandably) would not want to see that happen.

I believe the bottom line question here is "by giving information to someone that already had it, have I released nonpublic personal information?" I don't think so. It is common in many small towns for landlords to ask tenants to make their monthly rent payments by depositing the money in the landlord's account. The tenant needs the receipt to prove that they made their payment. How do you handle this if you won't give them a receipt?

One suggestion to David's question is to use the tactic suggested above: Mail the receipt to the account holder, and put the remitter's name on it.

If that won't work in your market, consider balances (definitely) and account numbers (your choice) from the receipts.

I agree that, if the person making the deposit already has the account number, printing it on the receipt doesn't let any cats out of any bags. But the balance print really can cause problems.