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#242824 - 09/09/04 04:55 PM
Re: Reg CC notices...Do we have to keep copies??
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Platinum Poster
Joined: Feb 2002
Posts: 582
USA
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Did the seminar presenter say by whom it's not required? Both our auditors and examiners ask to see our copies of hold notices. It was suggested that we attach copies of the check(s) in question to our copy of the form.
Maybe the requirement isn't there technically but since we're always asked for copies, it close enough to a requirement for me.
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#242831 - 09/09/04 06:07 PM
Re: Reg CC notices...Do we have to keep copies??
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10K Club
Joined: Sep 2002
Posts: 13,965
TN
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We keep copies of the hold notices along with copies of the item(s) deposited. They really like this when performing a review. Also, the head of retail went to a seminar yesterday and was told that this will be covered more in upcoming exams.
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#242833 - 09/09/04 07:21 PM
Re: Reg CC notices...Do we have to keep copies??
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Platinum Poster
Joined: Feb 2002
Posts: 582
USA
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It seems to me that you can't erase the past so you just have to live with the write-up and vow not to make the same mistake again. I think that, since you've been written up once for an error, they will be disturbed if you suddenly explain that you don't need to keep copies anymore.
I don't see the "if we hadn't made copies, they wouldn't have found the error" as a valid argument.
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#242835 - 09/11/04 08:54 PM
Re: Reg CC notices...Do we have to keep copies??
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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From the Commentary to Reg CC:
A bank is not required to retain records showing that it actually has given disclosures or notices required by this subpart to each customer, but it must retain evidence demonstrating that its procedures reasonably ensure the customers' receipt of the required disclosures and notices. A bank must, however, retain a copy of each notice provided pursuant to its use of the reasonable cause exception under Sec. 229.13(g) as well as a brief description of the facts giving rise to the availability of that exception.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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#242836 - 10/12/04 06:37 PM
Re: Reg CC notices...Do we have to keep copies??
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Anonymous
Unregistered
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Ken--right on top of everything as always! One of the most common errors I note when conducting compliance exams at our banks is failure to document the facts leading to the hold. If Bob at ABC Bank was called and indicated the check was not good--write it down on our copy of the check or hold notice and retain it with a copy of the hold notice. If you are placing the hold late because you identified possible kiting the next day, place the hold and document that the customer appears to be drawing on uncollected funds. Document, document, document!
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