I am currently beginning an audit regarding dormant accounts for a financial institution that was recently acquired through the FDIC, and can’t determine whether it is appropriate for the date of last contact for deposit accounts to become the acquisition date of the previous date, or whether the date previously tracked should be maintained. What about when the acquired bank converts from one processor to another? Is it sufficient for the last contact date to revert to the conversion date?

In both situations, letters are sent to the customer; specifically, when a bank acquires another through the FDIC, there is usually an Unclaimed Deposit stipulation in a Loss share agreement that requires the acquiring bank to send notifications to customers in order to claim their accounts. As such, is the mailing of the notification considered contact, or would it only constitute contact if the customer replied to the letter? Most conversion letters are, at most, negative assurances, as it’s unlikely that a customer would need to have an active role in the conversion process.

I would greatly appreciate others’ perspectives on this. Thanks in advance.

whether the date previously tracked should be maintained - Yes

Is it sufficient for the last contact date to revert to the conversion date? - No

Whether the mailing of the letter/notice would be contact will be based on State law, but the communication usually has to go in the other direction.