Thread Options Tools
#2256025 - 06/28/21 01:40 PM Where to Post Disclosures
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 3,965
New York City
Currently our disclosure board is posted behind the teller line (There are some smaller disclosures, Member FDIC, insured up to $250,000, and fund availability posted at our ticket board). Audit is citing us and indicating the some customers may not be able to see the disclosures. Naturally we disagree and feel the board and the associated disclosures can be viewed.

Has anyone had any experience with this? I know the disclosures need to be observable but we believe anyone who conducts a banking transaction can see the disclosures.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

Return to Top
General Discussion
#2256027 - 06/28/21 01:50 PM Re: Where to Post Disclosures ACBbank
Skittles Offline
10K Club
Skittles
Joined: Sep 2002
Posts: 13,962
TN
While this is visible for anyone coming in to do a banking transaction - are they visible to anyone coming into the branch? Not everyone goes to the teller line.

A bank I worked for years ago was cited for not having the CRA signage visible to individuals who came in to meet with a loan officer. It was only visible if a person was doing a teller transaction.
_________________________
My Opinions Only

Return to Top
#2256031 - 06/28/21 02:08 PM Re: Where to Post Disclosures ACBbank
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 77,310
Galveston, TX
Well a disclosure board behind the teller is sort of a open-end statement, without being able to see what you are talking about and knowing the exact signage you are referring too, it is hard to say.

For Regulation CC - does it really meet the requirements? What is a "ticket board": The notice need not be posted at each teller window, but the notice must be posted in a place where consumers seeking to make deposits are likely to see it before making their deposits. For example, the notice might be posted at the point where the line forms for teller service in the lobby.

Having an FDIC sign on a "ticker board" is likely not going to cut it: (a) Display of official sign. Each insured depository institution shall continuously display the official sign at each station or window where insured deposits are usually and normally received in the depository institution's principal place of business and in all its branches.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2256063 - 06/28/21 06:55 PM Re: Where to Post Disclosures ACBbank
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 3,965
New York City
What I meant by ticket board is where our deposit slips are located. It's in the middle of this particular branch and visible upon walking into the branch.

I'll take note of the other points made in this thread.

Thanks.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

Return to Top
#2256065 - 06/28/21 07:04 PM Re: Where to Post Disclosures ACBbank
Skittles Offline
10K Club
Skittles
Joined: Sep 2002
Posts: 13,962
TN
Do you have the 'Member FDIC' sign at each teller taking window?
_________________________
My Opinions Only

Return to Top
#2256066 - 06/28/21 07:08 PM Re: Where to Post Disclosures ACBbank
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 77,310
Galveston, TX
Just be aware that being visible and where consumers "are likely to see it" leaves a lot to be interpreted by auditors and examiners. Me - I have my deposits ready to go and never even glance at the ticket counter. The coffee pot on the other side of the branch is also visible, but I can't tell what brand of coffee they are making.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top