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Daily Monitoring System for Excessive Transactions

Answered by: 
John Burnett

Question: 
Our institution monitors transactions for Reg D purposes only at the end of the month. We are looking into changing it to monitor daily, but what if the customer has excessive transactions three days in a row and the account is converted before the customer receives the change notice? We'd like to know if there's a better way to do this. Is there a sample that will show us how to create a daily monitoring system?
Answer: 

You don't have to convert or close the account based on three successive days of exceeding the limit. Just start your communication with the customer as soon as you detect excessive transactions and have something in your policies and procedures that will alter the account if the customer becomes a flagrant violator before month end. Allow time for the customer to learn of the problem and change behavior before you drop the hammer, but don't be too lenient with folks who clearly show an intention to ignore the limitations.

First published on BankersOnline.com 2/02/09

First published on 02/02/2009

Filed under: 
Compliance
Filed under compliance as: 
IT
Policies

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