The Bank's auditor recently noted a "finding" that Closing Instructions were not in file.

Is this a regulatory requirement in any way, or are there regulatory considerations of which I'm unaware?

Thanks for any help!

If this concerns deposit account closings, I'm not aware of any regulatory considerations. If we know the customer wants the account closed,and they come to our new accounts staff, we generally use a close-out slip so we have a signature that they wanted the account closed and got their money.

However, if they just withdraw the money, the account will close out automatically after a certain number of days with a zero balance and there are no 'closing instructions' anyway.

However, if you have it in your policy that you need such instructions, and that's what he/she is criticizing, that's another matter.

Ho

Thanks for responding. Unfortunately, this concerns closing instructions for a mortgage. I'm thinking it's basically something the auditors have gotten used to seeing in file, and then, when it wasn't there on one file for whatever reason..."finding!"

Well, it is not a regulatory issues, but most banks have executed closing agreements with the title companies, either blanket agreements further supported by a closing letter or standalone closing agreements. If something down the road indicates that the closing was screwed up by the title company, without a copy of the agreement you are going to have a hard time holding their feet to the fire.