Letter to Credit Union No. 16-CU-04: Member Account Deposit Reconciliation Practices
May 2016

NCUA issued guidance (together with four other federal financial regulatory agencies) to address discrepancies that may occur with amounts deposited by a member and the dollar amount credited to that account. At issue is the circumstance when a customer makes a deposit to an account but the credit union (or bank) credits a different amount to the account. This may happen as a result of inaccuracies on the deposit slip, encoding errors, or poor image capture. The enclosed “Interagency Guidance Regarding Deposit Reconciliation Practices” discusses consumer protection laws applicable to deposits, including:

  • Expedited Funds Availability Act (as implemented by Regulation CC)
  • Federal Trade Commission Act
  • Dodd-Frank Wall Street Reform and Consumer Protection Act

The guidance establishes NCUA’s supervisory expectations regarding customer account deposit reconciliation practices. NCUA expects credit unions to adopt deposit reconciliation policies and practices that are designed to avoid or reconcile discrepancies, or designed to resolve discrepancies such that members are not disadvantaged. NCUA reminds credit unions that failure to implement policies and procedures to mitigate potential harm to their members from deposit discrepancies may result in numerous consumer compliance violations.

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