FDIC Common Deposit Violations
In November, we had the pleasure of attending the 2019 Iowa Bankers Association Compliance Conference. One of the breakout sessions addressed common errors and findings from the FDIC. Whether you are FDIC regulated or not, any time you have access to a regulator’s common violations, it’s a great opportunity to review them and ensure you are not making the same mistakes at your financial institution.
- Truth In Savings Act
Many of the common violations noted had to do with system updates. If you customize your software, for example, so that fee terminology on your periodic statements matches your account opening disclosures, make sure when you get a system update that those changes are still in place. Financial institutions often don’t think to check this and unfortunately, examiners are typically the ones to find the problem.
2. Electronic Fund Transfer Error Resolution
The FDIC continues to see the following violations:
- Employees not immediately sending error notices to the appropriate department for timely investigation and resolution;
- Requiring a consumer to provide a written or signed confirmation of the error before initiating an investigation;
- Requiring a police report or a signed fraud affidavit before initiating an investigation;
- Requiring the consumer to work with the merchant prior to investigating an EFT error; and,
- Not notifying consumers when an investigation has been completed and giving them the results of the investigation.
Be sure to check out our webinars that are available On Demand. We offer webinars on a variety of deposit topics including both the Truth in Savings Act and Regulation E: Errors & Disputes.
Published
2020/01/21
Kevin Edwards
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).