On May 18, 2016, five federal banking agencies—the Board of Governors of the Federal Reserve System (“Board”), the CFPB, the FDIC, the NCUA, and the OCC (collectively, the “Agencies”)—issued a supervisory bulletin titled “Interagency Guidance Regarding Deposit Reconciliation Practices” (the “Guidance”). The Guidance outlines supervisory expectations for financial institutions’ investigation and resolution of “credit discrepancies” when customers make deposits in their checking and other deposit accounts.
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