We went to a new system in 2021 and some of the tellers are still confused about the interest to be paid at closing. Some interest bearing accounts were closed and were not paid the interest due them. Should we correct this and give the customers the interest amount when it is between.01 and $1.00 - some of these customers no longer have accounts with us or are deceased. We will be crediting the customers that still have accounts with us. Some customers closed their savings accounts and interest checking accounts on line. I do not feel we need to give them the interest on these accounts closed by the customer on line.

IMO, it is unreasonable to retain interest that was earned by the customer, regardless of how the account was closed. Even if the customer closed the account online, the bank processed the closure and applied (or should have applied) accrued interest belonging to the customer.

If you did not disclose the fact that you were not going to pay accrued interest at the time of closure, then get out your check book and make the payments. The regulators will require you to if they figure it out.

1030.7(b) - Comment 3. Closed accounts. Subject to state or other law, an institution may choose not to pay accrued interest if consumers close an account prior to the date accrued interest is credited, as long as the institution has disclosed that fact.