CFPB Issues Bank Account Deposit Discrepancy Guidelines


On Wednesday (May 18), the Consumer Financial Protection Bureau said that it, along with four other federal regulatory agencies, issued guidance covering the oversight of consumer deposit discrepancies. The agencies said that the interagency guidelines state that the banks should “avoid or reconcile” what is credited to a customer account and how much was deposited.

Banks, according to the guidance, must adopt policies that are governed by “fairness” as consumers make deposits that do not violate law.

In the event that there is a discrepancy — as in when the sum that the bank credits to the account may be different from the amount that is deposited — the root causes may extend to written tallies that are off the true mark or poor image capture by the bank when a deposit slip is scanned. That points to some of the limitations of technology.

In the event that a financial institution fails to keep pace with the regulations that are put in place, it can be found liable and subject to action from one of the five agencies, a roster that includes, beyond the CFPB, the Federal Deposit Insurance Corp., the National Credit Union Administration, the Office of the Comptroller of the Currency and the Federal Reserve. The consortium said it had taken action against Citizen’s Bank NA for failure to credit the full amount of funds to some of its client accounts, which led to a consent order with $11 million in refunds and an additional $7.5 million penalty tied to those violations.


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