Bankers Alliance Compliance Corner
Editor's Note: The following was submitted by Bankers Alliance. LBA, through its subsidiary Louisiana Bankers Service Corporation, has partnered with Bankers Alliance to give banks access to three compliance-related programs. Click here for more information.
Q: Are banks required to provide a monthly statement to customers for demand deposit accounts even if there is no activity occurring?
A: Internal policy may require a monthly statement regardless of activity level, but Regulation E requires a periodic statement for accounts to or from which electronic funds transfers can be made for each monthly cycle in which an electronic funds transfer has occurred. If there is no activity in a month then a statement is not required but a statement must be sent at least quarterly, so at least every three months even if there is no account activity. Click here for more information.
Q: If we cancel a customer's debit card do we have to notify them?
A: Per Regulation E commentary, the cancellation of an access device is a change that does not require disclosure. Click here for more information. The only prohibition/requirement would come from the account agreement so you'll have to confirm with the agreement before proceeding.
Compliance Alliance offers a comprehensive suite of compliance management solutions. To learn how to put them to work for your bank, call (888) 353-3933 or email firstname.lastname@example.org and ask for the membership team.
Did you know that account disclosures should be matched to system settings regularly?
- Truth in Savings disclosures let customers know how interest will be calculated and when it will be credited to their accounts.
- Core processing systems may differ from the system that generates account opening disclosures.
- It is important to reconcile disclosures to core systems to help ensure accuracy.
Did you know that specific employee names are best left out of written procedures?
- When creating procedures, listing only the job title responsible will prevent the bank from needing to update procedures due to staffing changes.
- Procedures can be specific, but the employee responsible should be generic—i.e., compliance officer.
Review Alliance is an independent group of compliance specialists offering banks deep-dive audits of their existing transactions, recommendations about program enhancements or guidance on future safety and soundness. Virtual Compliance Officer was added in 2020—a new shared service-model using bank-dedicated compliance officers; perfect for monitoring and guiding your bank remotely. To learn how to put them to work for your bank, call (833)-683-0701or email email@example.com and ask for the membership team.