On-Premise Night Depository

On-premise night depository - deposits made to a night depository should be credited up to the business day cut-off, is that correct? Or, once per day is sufficient? (Typically checked in the morning at start of the business day)

The commentary under Appendix E suggests to me that we should be checking the night depository before the end of our business day to ensure proper crediting of deposits. Thanks in advance.

If an unstaffed facility, such as a night depository or lock box, is on branch premises, the day of deposit is determined by the banking day at the branch at which the deposit is received, whether or not it is the branch at which the account is maintained.

Yes - On premise facilities need to be checked at the end of the business day cut-off.

Thank you.

Does any signage posted at the night depository, such as "Deposits made after 9AM credited next business day" matter? I'm getting questioned on this while completing a review, and not sure what else to provide other than the commentary to the regulation. ??

You cannot alter the Regulation CC requirements with a sign. Good lord, it has been this way since 1988 - not sure where these people have been? .

Ha! But that's the way it's always been!

Well, make sure to mention that if a violation of the regulation that has been happening for the last 34 years is not a pattern or practice, you are not quite sure what might fall into that category

For those of us that were actually around doing compliance and training bank personnel in the summer and early fall of 1988 getting ready for the kick-off, this was one that we really had to hammer on, as every branch that we had emptied the night depository in the morning and then forgot about until the next morning. They really had to change their habits.

If your bank has ATMs that image deposited checks (envelopes aren't used), and if you are able to remotely pull those images from the ATM for purposes of clearing them, you may not need to service the ATMs every banking day, making time-of-day for cutoff later in the day quite easy.

Thank you both for the information!

Our proprietary ATMs do not accept deposits, so one less thing to worry about.
The discussion we are currently having relates to the night depository boxes that are located on bank premises.

So, let me get this straight in my head, because I'm not sure we are doing this correctly, even if it has been this way since 1988. We have night depository boxes located at all of our branches. They are opened first thing in the morning (approximately 8:30 am) and all transactions are processed. We do not open it again that day. We do not have a cut-off time, we close at 5:00 pm. Are you saying we should be opening these night deposits again and processing any transactions that may have been put in them through out the day, prior to closing at 5:00 pm?

If so...how did we miss this!?

(I just want it to be known that I was a freshman in HS in 1988)

Yes - that is what is required. How did your bank miss it - not really sure.

Thank Randy! I appreciate the clarification.

And I didn't really expect you to know how we missed it......LOL

You aren't the only one Bankwoman1! I've worked at two FIs and spoke to other team members that have worked at different FIs. Seems none of us were aware of this.

Thanks for making me feel better Valley girl . I've worked at two different FI's and we haven't done this at either place!

I've worked in 6 different banks over the last 19 years & have never heard of this. Every one only checked the night depositories first thing in the morning. Apparently it's not a hot topic with examiners?

I have been doing this for 43 years starting out at a Savings and Loan and we only checked once in the morning and still only do once in the morning with a night deposit log. Also worked for one of the biggest banks in the US and only opened once in the morning. Heaven forbid we should touch it again until the next day. Have never had an auditor or an examiner question it.

Ditto to prior responses, two employees open, count, log night drop in the morning. No mention of this has ever been made in any audits or exams. Honestly at our bank you have to drive thru the drive-up window lane to use the night drop and/or ATM; so we know who you are if it happens.