Summary outlines letter on deposit reconciliations

June 7, 2016 – Guidance to address discrepancies that may occur with amounts deposited by a member or customer and the dollar amount credited to that account, is addressed in a new Letter to Credit Unions from NCUA, issued May 18.

NASCUS has posted a summary of the letter (available to members only).

The “Interagency Guidance Regarding Deposit Reconciliation Practices” issued by NCUA (as LTCU 16-CU-04) and four other federal financial regulatory agencies, discusses consumer protection laws applicable to deposits, including the Expedited Funds Availability Act (as implemented by Regulation CC), the Federal Trade Commission Act, and the Dodd-Frank Wall Street Reform and Consumer Protection Act. The guidance notes that violations could occur if “credit discrepancies” are permitted or not resolved in a timely manner.

The guidance, NCUA notes, does not mandate specific practices. However, the agency states, “it does emphasize the need to reconcile variances resulting from encoding errors, poor image capture, and other issues.”

NASCUS summary, LTCU 16-CU-04