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#645806 - 12/01/06 07:26 PM Dormant Accounts
txgal, CRCM Offline
Junior Member
Joined: Jul 2006
Posts: 44
Texas
I am starting an audit of Dormant account and will use the Dormant Account Audit Program from Bankers Tools. Can someone please explain to me why the Bank would send positive confirmations? This is the first audit performed on dormant accounts.

Any help is greatly appreciated.

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#646318 - 12/04/06 02:37 PM Re: Dormant Accounts txgal, CRCM
Cornfed Turtle Offline
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Joined: Mar 2006
Posts: 1,323
"...Somewhere in Middle Americ...
Don't know if this is the right answer, but my thinking is that these people haven't come in, mailed in or answered anything else from you, if they tossed out a negative confirmation, you wouldn't gain anything. The confirmation would serve no audit purpose if they were just given the opportunity to ignore another piece of mail from you.

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#653940 - 12/18/06 10:52 PM Re: Dormant Accounts Cornfed Turtle
Mommadeb Offline
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Joined: Aug 2006
Posts: 4
If you want to hear from them, institute a dormant account fee. We have many many small dormant accounts. We enacted a $4 dormant account fee. First we disclosed it on our website and our newsletter and statement stuffer. We waived the fee if their balance is over $1,000, if they are a minor, or if they have a CD or an IRA type account also. Not only did we hear from many people that had forgotten all about us, we boosted our income!

We agreed to refund one statement cycle's fees when they brought the account active. You would be surprised how many people had a year's charges or more before they even looked at their quarterly statements - then complained. But, we have less dormant accounts now!

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#653952 - 12/18/06 11:28 PM Re: Dormant Accounts Mommadeb
Al Miller Offline
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Al Miller
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Posts: 2,416
Pleasanton CA USA
Check state law before instituting a fee. It is illegal in CA to charge a fee just because an account is inactive.

Al
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Al Miller, CRCM
Opinions expressed are my own and not necessarily shared by my employer.

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#653984 - 12/19/06 01:14 PM Re: Dormant Accounts Al Miller
Andy_Z Offline
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Texas is the same in that you can't cause the account to be devalued. Texas uses "inactive" I believe, in place of the term "dormant." So watch any keyword searches too.
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#656592 - 12/22/06 08:03 PM Re: Dormant Accounts Andy_Z
scout Offline
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Joined: Jan 2006
Posts: 14
Does it make a difference if you are a national bank and the OCC permits charging dormant accounts; therefore superceding state law?

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#657079 - 12/26/06 05:24 PM Re: Dormant Accounts scout
Al Miller Offline
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Al Miller
Joined: Oct 2000
Posts: 2,416
Pleasanton CA USA
Many years ago, possibly before the thought of federal preemption, the decision against BofA made it abundantly clear that service charges could continue on dormant account, but that any new charges, including increasing charges on existing accounts, was not allowed.

That was so long ago that BofA was only in CA.

Being relatively new to OCC regulation, could you please provide a cite stating that national banks can impose such a fee.

Al
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Al Miller, CRCM
Opinions expressed are my own and not necessarily shared by my employer.

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#657249 - 12/26/06 07:54 PM Re: Dormant Accounts Al Miller
Andy_Z Offline
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Here is some old discussion on the topic. See my comments about an unofficial opinion I'd read about, in this Texas thread.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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