Compliance Bulletin

Federal Banking Agencies Issue Guidance on Reconciling Deposit Discrepancies
May 23, 2016

The CFPB and the federal prudential banking regulators issued guidance on reconciling credit discrepancies, including within the prescribed time frames under the Expedited Funds Availability Act and Regulation CC. The guidance is related to a consent order against Citizens Bank of Pennsylvania over its practice of not reconciling to the penny discrepancies between amounts stated on customer deposit slips and actual deposits. The guidance appears to suggest that a failure to grant availability to the full amount of a covered deposit transaction may trigger a violation of Regulation CC, exposing a bank to civil liability and possible action by a banking agency. See CBA’s Regulatory Compliance Bulletin, prepared by Ted Teruro Kitada, Senior Counsel to Wells Fargo Bank and Chairman of CBA’s Legal Affairs Committee for more information.