I suggest that the bank review its procedures and consider delaying any similar transaction to the 7th day from opening.
For this one, I suggest you might consider that the account never truly was opened, particularly if no interest was included in the return of the depositor's funds. At least that's the argument I'd use if challenged by an examiner.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8