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Reg E: Rounding Up If Interest Owed Under 1 Cent?

Answered by: 
John Burnett
Andy Zavoina

Question: 
In reference to this discussion: Question: I am currently going through a review of ATM/Reg E procedures with our internal Compliance dept. They are requesting that we apply interest to disputed Reg E amounts because of the Deposit Compliance Program. I have not heard of having to apply interest to disputed Reg E transactions. Should we be applying interest on transactions that are disputed under Reg E?Answer: Yes, you are required to credit a customer for lost interest when they make a Reg E claim. This is addressed in <a href="http://www.bankersonline.com/regs/12-1005/12-1005-011.html">1005.11(c)(2)(i)</a>The question I have is...if the interest owed is less than one cent, do you still have to post it by rounding it up to one cent?
Answer: 

Answer from John: If the calculated amount is less than one cent, I'd suggest rounding down (to zero) or up (one cent) based on the standard rounding routine. Document the procedure and follow it.

Answer: 

Answer from Andy: Being consistent is the most important thing. These occasions will likely be minimal and if you want to standardize it for the "math challenged" just always round up.

First published on BankersOnline.com 3/25/13

First published on 03/25/2013

Filed under: 
Compliance
Filed under compliance as: 
IT

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