Has anyone received guidance on complying with AB 1527, which prohibits banks from issuing an account number to a consumer that had previously been held by another customer within the last three years? How can a bank that legally purged closed account data prior to the law's enactment now be expected to rely on account data that doesn't exist?

While thinking about purging depositor information, remember that at least 1 §314(a) search request required records be searched back 3 years.

If you a lucky enough to not be familiar with §314(a), go to the BSA thread.


Al

We do keep sufficient information for §314(a) requests, but the requirements of AB 1527 go beyond what we have retained.