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#194989 - 05/27/04 10:32 PM DDA overdraft repayment
Compliance99 Offline
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Compliance99
Joined: Jul 2003
Posts: 53
Washington
If a customer makes a payment to reconcile an overdraft on a DDA, is there any specific regulation stating when the payment is considered received, or for what date it should be effective dated? This question applies specifically to DDAs without overdraft credit lines. Thanks.

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Operations Compliance
#194990 - 05/27/04 11:17 PM Re: DDA overdraft repayment
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,388
Galveston, TX
I'm curious as to what difference it would make? It's not like there are additional late fees or interest charges. I would assume that you would post it to your recovery account the day you received it.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#194991 - 05/28/04 03:30 PM Re: DDA overdraft repayment
Compliance99 Offline
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Compliance99
Joined: Jul 2003
Posts: 53
Washington
Good point, and one I keep running into. I'm auditing our DDA recoveries department. Suppose that it's the final day before the overdrawn account is charged off, and a payment comes in. But instead of being stamped as received on the day it is reveived by the bank, it is not stamped as received until two days later, when it actually makes it to the recoveries department. Unlikely, yes, but possible. Just covering all my bases (I hope). On top of that, difference or not, the audit is for compliance with federal requirements - that's my real goal.

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#194992 - 05/28/04 03:35 PM Re: DDA overdraft repayment
Paragon Offline
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the audit is for compliance with federal requirements - that's my real goal.




What requirements? It appears that this is strictly an internal issue with each bank deciding how to handle OD collections, including not pursuing collection at all.

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#194993 - 05/28/04 03:50 PM Re: DDA overdraft repayment
Compliance99 Offline
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Compliance99
Joined: Jul 2003
Posts: 53
Washington
Quote:

is there any specific regulation stating when the payment is considered received, or for what date it should be effective dated? This question applies specifically to DDAs without overdraft credit lines.




Paragon, my question has always been: are there any regulations governing this? If there are, those are what I'm looking for. If there are none, I would like to be able to definitively state as much to my supervisors.

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#194994 - 05/28/04 03:57 PM Re: DDA overdraft repayment
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,388
Galveston, TX
There are none - otherwise why would I have indicated what difference does it make? The only governing principals would GAAP, depending on whether the account is or is not charged-off at the time of posting.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#194995 - 05/28/04 04:07 PM Re: DDA overdraft repayment
Paragon Offline
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Paragon
Joined: Dec 2003
Posts: 2,164
As noted above, there are none. Normally, one starts with a law or regulation as a reason to audit 'something' and if there are none, one starts with an internal control or policy - so what you are looking for is something internal that impacts an operational event.

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#194996 - 05/28/04 04:19 PM Re: DDA overdraft repayment
Compliance99 Offline
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Compliance99
Joined: Jul 2003
Posts: 53
Washington
Quote:

There are none - otherwise why would I have indicated what difference does it make? The only governing principals would GAAP, depending on whether the account is or is not charged-off at the time of posting.




This is what I was looking for in the first place. Your asking what difference it makes didn't answer my question, so I asked it again. At any rate, thanks for your assistance.

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