Regulatory AlertsInteragency Guidance Regarding Deposit Reconciliation Practices
The Federal Reserve Board, CFPB, FDIC, NCUA, and OCC issued interagency guidance establishing supervisory expectations for deposit reconciliation practices at state member banks. The document emphasizes compliance with the Expedited Funds Availability Act and Regulation CC regarding prescribed time limits for making deposited funds available for withdrawal. It also highlights the prohibition against unfair or deceptive acts or practices under the Federal Trade Commission Act.
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CA 16-2: Interagency Guidance Regarding Deposit Reconciliation Practices
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM WASHINGTON, D.C. 20551
DIVISION OF CONSUMER AND COMMUNITY AFFAIRS
CA 16-2
May 18, 2016
TO THE OFFICERS AND MANAGERS IN CHARGE OF CONSUMER AFFAIRS SECTIONS
SUBJECT:
Interagency Guidance Regarding Deposit Reconciliation Practices
Applicability to Community Banking Organizations:This guidance applies to all state member banks supervised by the Federal Reserve, including those with total consolidated assets of $10 billion or less.
The Federal Reserve Board (Board), the Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency (collectively, the “Agencies”) have issued the attached interagency guidance to explain the Agencies’ supervisory expectations regarding institutions’ account deposit reconciliation practices. Among other things, the guidance highlights the requirement in the Expedited Funds Availability Act, as implemented by Regulation CC, 12 CFR Part 229, that financial institutions make funds that have been deposited in a transaction account available for withdrawal within prescribed time limits, as well as the Federal Trade Commission Act’s prohibition against unfair or deceptive acts or practices.
If you have any questions concerning this guidance, please contact Dana Miller, Senior Supervisory Consumer Financial Services Analyst, at (202) 452-2751, or Amy Henderson, Managing Counsel, at (202) 452-3140. In addition, questions may be sent via the Board’s public website. [1]
signed by Eric S. Belsky Director Division of Consumer and Community Affairs
Attachments:
Interagency Guidance Regarding Deposit Reconciliation Practices
Notes:
[1] See http://www.federalreserve.gov/apps/contactus/feedback.aspx .
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Last Update:
April 20, 2017