Agencies Outline Supervisory Expectations for Deposit Reconciliation Practices

The Office of the Comptroller of the Currency, the CFPB, the FDIC, and the National Credit Union Administration (the "Agencies") outlined supervisory expectations regarding deposit reconciliation practices for customer accounts. In a new guide, the Agencies discuss the variety of circumstances that can lead to discrepancies in the amount that the financial institution credits to an account including inaccuracies on the deposit slip, encoding errors, or poor image capture. Technological and other processes exist that allow financial institutions to fully reconcile these discrepancies.

The agencies expect national banks and federal savings associations to:

• adopt deposit reconciliation policies and practices that are (i) designed to avoid or to reconcile deposit discrepancies, or (ii) designed to resolve discrepancies in such a way that customers are not disadvantaged;

• effectively manage their deposit reconciliation practices to avoid violations of laws and to prevent potential harm to their customers; and

• implement effective compliance management systems, including appropriate policies, procedures, internal controls, training, oversight, and review processes to ensure compliance with applicable laws and fair treatment of customers.