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#1519755 - 03/09/11 10:23 PM Christmas Club Compliance
Ginlyn, CRCM Offline
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Ginlyn, CRCM
Joined: Nov 2003
Posts: 300
Oklahoma
Our bank has several Christmas Club accounts, mostly with preauthorized inter-bank transfers. However, if a Christmas Club account customer makes a deposit in person by cash or check, does that trigger a monthly statement to be generated and sent?
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Ginger M CRCM

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Operations Compliance
#1519967 - 03/10/11 03:31 PM Re: Christmas Club Compliance Ginlyn, CRCM
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Do you mean intra-bank transfers?

Inter-bank transfers would trigger Regulation E statement requirements.

As for your question, though, deposits by check or cash don't by themselves trigger a statement requirement unless there's a state law that says so.
Last edited by John Burnett; 03/10/11 03:34 PM.
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#1520019 - 03/10/11 04:11 PM Re: Christmas Club Compliance John Burnett
Ginlyn, CRCM Offline
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Ginlyn, CRCM
Joined: Nov 2003
Posts: 300
Oklahoma
I'm talking about customers who come into the bank and make a deposit of cash or check at a teller station. Most of our Christmas Club transactions are intra-bank and do trigger Reg E requirements; but what about the old fashioned deposit of cash or check -- does that trigger a statement?
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Ginger M CRCM

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#1520052 - 03/10/11 04:28 PM Re: Christmas Club Compliance Ginlyn, CRCM
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I think I answered that question. No. And those intra-bank transfers you describe probably do NOT trigger Reg E requirements. See Section 205.3(c)(5).
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#1520059 - 03/10/11 04:30 PM Re: Christmas Club Compliance John Burnett
Ginlyn, CRCM Offline
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Ginlyn, CRCM
Joined: Nov 2003
Posts: 300
Oklahoma
Thanks for the response and the cite.
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Ginger M CRCM

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