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#2256834 - 07/16/21 10:12 PM Error Resolution Credit of interest lost
t0dd Offline
100 Club
Joined: Sep 2004
Posts: 216
During a recent Regulation E audit we were cited for not crediting the interest lost on unauthorized funds on interest-bearing accounts. 1105.11(c) - comment 6 states the following: Correction of an error. If the financial institution determines an error occurred, within either the 10-day or 45-day period, it must correct the error (subject to the liability provisions of ยงยง 1005.6(a) and (b)) including, where applicable, the crediting of interest and the refunding of any fees imposed by the institution. In a combined credit/EFT transaction, for example, the institution must refund any finance charges incurred as a result of the error. The institution need not refund fees that would have been imposed whether or not the error occurred.

The interest lost in both instances was $0.01 and $0.02. I could not see anywhere in the regulation where there might be a minimum prior to reimbursement. Was curious how other banks are handling disputes and then crediting back lost interest.

Thank you in advance for your responses.

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#2256835 - 07/16/21 10:40 PM Re: Error Resolution Credit of interest lost t0dd
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 76,928
Galveston, TX
You don't really have a leg to stand on. You owe them the interest according the regulations. Whether $.01 or $100.00 it is all the same. If you back date the credit, does your deposit system not automatically give them credit? It does not need to be a separate entry.
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