[Chris]

My question pertains to the letters used to notify customers with money market or savings accounts when they have exceeded the Reg D limitations on withdrawals.

I cannot locate anything in the Regulation stating that we must keep copies of the letters. I also could not locate any FDIC examination procedures for this area (we are FDIC-regulated).

Are we required to maintain copies of the letters? Or would it be sufficient to keep a “master copy” of the 1st warning letter, 2nd warning letter, and 3rd warning letter (which is when the account is closed or changed to a transaction account), and then maintain proof of letters sent by reports indicating as much or a log of some sorts?

[rcooper]

You will need to document that you have provided letters. If possible, I suggest maintaining the actual letters. However, I believe some banks do use the master letters/log process. I suggestion you have a conversation with your examiners to see what they expect and comply with that. In my opinion this isn’t an issue worth arguing and complying with their expectation will make your life easier.

[Author]

Posts