Where to Post Disclosures

Posted By: ACBbank

Where to Post Disclosures - 06/28/21 01:40 PM

Currently our disclosure board is posted behind the teller line (There are some smaller disclosures, Member FDIC, insured up to $250,000, and fund availability posted at our ticket board). Audit is citing us and indicating the some customers may not be able to see the disclosures. Naturally we disagree and feel the board and the associated disclosures can be viewed.

Has anyone had any experience with this? I know the disclosures need to be observable but we believe anyone who conducts a banking transaction can see the disclosures.
Posted By: Skittles

Re: Where to Post Disclosures - 06/28/21 01:50 PM

While this is visible for anyone coming in to do a banking transaction - are they visible to anyone coming into the branch? Not everyone goes to the teller line.

A bank I worked for years ago was cited for not having the CRA signage visible to individuals who came in to meet with a loan officer. It was only visible if a person was doing a teller transaction.
Posted By: rlcarey

Re: Where to Post Disclosures - 06/28/21 02:08 PM

Well a disclosure board behind the teller is sort of a open-end statement, without being able to see what you are talking about and knowing the exact signage you are referring too, it is hard to say.

For Regulation CC - does it really meet the requirements? What is a "ticket board": The notice need not be posted at each teller window, but the notice must be posted in a place where consumers seeking to make deposits are likely to see it before making their deposits. For example, the notice might be posted at the point where the line forms for teller service in the lobby.

Having an FDIC sign on a "ticker board" is likely not going to cut it: (a) Display of official sign. Each insured depository institution shall continuously display the official sign at each station or window where insured deposits are usually and normally received in the depository institution's principal place of business and in all its branches.
Posted By: ACBbank

Re: Where to Post Disclosures - 06/28/21 06:55 PM

What I meant by ticket board is where our deposit slips are located. It's in the middle of this particular branch and visible upon walking into the branch.

I'll take note of the other points made in this thread.

Thanks.
Posted By: Skittles

Re: Where to Post Disclosures - 06/28/21 07:04 PM

Do you have the 'Member FDIC' sign at each teller taking window?
Posted By: rlcarey

Re: Where to Post Disclosures - 06/28/21 07:08 PM

Just be aware that being visible and where consumers "are likely to see it" leaves a lot to be interpreted by auditors and examiners. Me - I have my deposits ready to go and never even glance at the ticket counter. The coffee pot on the other side of the branch is also visible, but I can't tell what brand of coffee they are making.