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Dodd-Frank Act and Night Deposits

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Does the Dodd Frank Act or compliance require banks to process loan payments that are dropped off in the night drop after the night drop has been closed for the day but the branch drive through is still open?

It depends on whether you have defined conforming payments and provided notice to your borrowers of what constitutes a conforming payment. You can define conforming payments as excluding night drop altogether or you can define it as including night drop with a specific cut-off time. In either case, if you've done that, then payments received that are not conforming need not be posted same day received.

First published on 10/25/2015

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