Financial Regulators Announce New Deposit Reconciliation Guidance
WASHINGTON — The five federal financial agencies released guidance on Wednesday that requires financial institutions to ensure they are addressing discrepancies customers sometimes face between the amount they deposit in their account and the amount they are credited.
This may cause “a detriment to the customer and a benefit to the financial institution if not appropriately reconciled,” states the guidance, which was issued jointly by the Federal Deposit Insurance Corp., the Federal Reserve, the Consumer Financial Protection Bureau and the National Credit Union Administration.
A common example, the agencies note, is when a customer deposits more than is indicated in their deposit slip.
“The customer may deposit $110 to an account, but may indicate on the deposit slip that only $100 has been tendered,” the guidance notes. “In this case, the financial institution may credit $100 to the customer’s account as indicated on the deposit slip without reconciling the $10 discrepancy.”
In other cases, the banks might make a mistake, as when they “do not research or correct all variances between the dollar value of items deposited … and the dollar amount that is credited,” the guidance says.
On the whole, financial institutions possess the resources to correct these mistakes through “technical and other processes,” according to the agencies.
The agencies said they would leave financial institutions off the hook in certain “limited” cases — “for example when an item is damaged to the point that its true amount cannot be determined.”
In the guidance, the agencies cite several laws and regulations that require banks to address such discrepancies through “deposit reconciliation.” Those include the Expedited Funds Availability Act, which holds that financial institutions must be transparent about their holding policies; and Section 5 of the Federal Trade Commission Act, which prohibits them from engaging in “unfair or deceptive acts or practices.”
Financial institutions must “adopt deposit-reconciliation policies and practices that are designed to avoid or reconcile discrepancies,” the guidance concludes, “or designed to resolve discrepancies such that customers are not disadvantaged.”
By Jillian Helgren, CheckAlt
It makes sense for banks and credit unions to augment CheckAlt’s ATM processing solution with our ATM reconciliation service to expedite and enhance their own internal processes.
The CheckAlt ATM processing solution automates the processing and consolidation of items received via image-enabled ATMs, which allows financial institutions to easily monitor check deposits, in near real-time. Additionally, to maintain control of the workflow, users are able to set business rules related to total deposit amounts, individual check amounts, duplicate suspects, amount changes, and MICR data matching. Items can be flagged for review, or appropriate action when necessary, before a check is processed forward.
With ATM processing our application is installed onto ATM terminals provided by Diebold, NCR, Nautilus Hyosung and Cummings Allison. When bank customers or credit union members deposit checks or cash into an ATM, the terminal creates a file, and CheckAlt’s application picks up the transaction and sends it to one of CheckAlt’s processing centers. Depending on how an institution sets up rules to review transactions, will determine if the transaction is automatically sent for processing or held until it is reviewed. At the end of the night we send the processed transactions for clearing.
CheckAlt ATM reconciliation is a service for banks and credit unions that enables them to settle their ATM terminals faster, identify missing deposits, transactions processed on a different date, and deposits that were removed from clearing.
By taking a match file from the financial institution’s terminal and running it against the transactions in CheckAlt’s item processing system, the bank or credit union is quickly able to identify deposit discrepancies.
CheckAlt ATM reconciliation consists of a series of reports designed to help in the settlement and reconciliation process, including a Matched Transaction Report, Exception Transaction Report, Other Processed Transaction Report and a Transaction Summary Report for accounting and balancing purposes.
These reports help banks and credit unions know whether or not they are out of balance and why. Without this, institutions either do this reconciliation process manually or they just don’t do it at all.
If they reconcile manually, on a daily basis they will have to compare the information from CheckAlt to the information from their core system. And if they find that they are out of balance, they may not know the cause and they will have to research it further. Sometimes they don’t have the information readily available, so determining the cause can become much more cumbersome.
Whereas, if they were to add our ATM reconciliation service, banks and credit unions don’t have to wait on answers – our ATM reconciliation service makes it easier for institutions to balance out their terminals on a daily basis.
And reconciling accurately on a daily basis is now even more critical, as five federal regulators have just issued an interagency guidance regarding deposit reconciliation practices. The agencies wrote that they have observed that financial institutions use a variety of approaches to handle credit discrepancies.
“In some instances, financial institutions do not research or correct all variances between the dollar value of items deposited to the customer’s account and the dollar amount that is credited to that account, resulting in the customer not receiving the full amount of the actual deposit,” the agencies wrote. “The agencies expect financial institutions to adopt deposit reconciliation policies and practices that are designed to avoid or reconcile discrepancies, or designed to resolve discrepancies such that customers are not disadvantaged.”
Talk to your CheckAlt representative to learn more about how our ATM reconciliation service can not only expedite but also enhance your internal procedures.
Currently Checkalt’s ATM services are conducted for 3,000-plus ATMs nationwide.
By Michael Duncan, founder and chief executive officer of Bankjoy, a CheckAlt portfolio company
Financial institutions wanting to court Millennials would be well-served to ask them what they actually want from an institution – and how they want to be approached.
This is a basic tenant for interacting with the younger generation, no matter the financial product or service. But it might be especially important to remember when figuring out how Millennials want to interact within an institution’s digital channels.
Take mobile banking apps. Unfortunately, user interfaces and user experience seem to be an after-thought in many cases when it comes to consumer-facing products provided by banks and credit unions. Few institutions take the time to gauge people’s opinion about certain features before launching them, but instead take stabs in the dark about what might be popular – only to experience weak adoption afterward.
But at Bankjoy, we bring in focus groups and ask them to interact with our user interface, and then we make adjustments. For example, to counter low adoption of apps that first show a menu after logging in, we asked people what they wanted to see first. Overwhelmingly, they valued viewing their account balances before anything, even a menu. This is especially true for the Millennials we asked — that’s an example of taking user interface serious and not being an afterthought.
Now take personal financial management tools on mobile apps. Most banks and credit unions that provide such tools believe customers prefer making financial decisions themselves, after viewing all of the data from their various accounts aggregated into one app. Institutions try to facilitate their customers’ financial decisioning by creating separate categories of expenditures, such as groceries and travel, so customers can better gauge just where they are spending money. Many institutions are stuffing as much data as they can into their PFM apps, seeing that as an advantage.
But for Millennials, that’s simply not enough. Millennials are now saying loud and clear that they would rather institutions help them actually manage their finances and also tell them what to do with their money.
According to the results an Accenture survey of nearly 4,000 retail banking customers published in the report, “The Digital Disruption in Banking: Demons, Demands, and Dividends,” 67% of respondents who were 18 to 24 years old said they were interested in their institution providing tools and services to help them create and monitor a budget. What’s more, 58% of respondents said that they wanted their institution to proactively recommend products or services to them that they might find useful.
Millennials also want to know what they need to do to achieve their goals – for example, right after college graduation, should they focus strictly on paying off their student debt or should they also start investing while servicing the debt at the same time? Which investments make the most sense?
We’re creating new features within our apps so institutions can better meet the needs of Millennials.
First, we have a way for customers to identify their savings goals to make it much easier for them to accomplish them, whether it’s saving for a car, or a home, or a trip to Paris. We let customers plug whatever savings goals they may have within the app, and we try to make it as personal for them as we can, letting them name their goals and even apply pictures to that goal that they have uploaded from their own files or from social media. A growing body of research has shown that the more a person can concretely visualize their goals, the more they can visualize – and then take – all of the steps necessary to achieve those goals. We allow users to decide how much to save and how often. The bank or credit union knows how much each user is saving each week or month.
Then we’ve developed the capability within the app for institutions to make personalized offers to these customers, such as a loan, or personalized financial advice to help them achieve that goal faster.
If a bank or credit union wants to offer loans to customers who have saved a certain amount of money, we provide them with the admin tool to automatically create ad campaigns, based on criteria the institution inputs. For example, an institution can ask for all customers who have created a goal to save for a car, and then ask for only those who have saved, say, $2,500, which could enable them to use that as a down payment for a loan to buy a car. Banks’ marketing departments can design and upload images for ads.
We have three channels, mobile banking, online banking, and statements, in which ad campaigns can be distributed. Banks can link ads to pages on their website or to features in the apps. For example, we can create an ad that sends the user to the goal creation feature in the app to create a goal to save for a particular item.
Banks and credit unions can also give customers personalized advice on how to best achieve their savings goals. Through our admin tool, they can find who they want to target, and then send advice through the apps or printed on electronic statements. For example, institutions can target customers who have created a goal to save for a house, and then send tips, such as letting customers know the institution’s maximum debt-to-income ratio to give them an idea on how much credit card debt they should pay down before actually applying for a mortgage.
For Millennials in particular, they may have money in their account, but they may not have any idea on how to achieve their goal without help. Institutions can give them targeted messages about their ability to help these customers achieve their goals. We don’t dictate the type of advice – we let banks do their job. But we provide banks with the capability of full transparency on what customers are saving for.
Our white-labeled app can be downloaded for free from iTunes or the Google Play Store for iOS devices and Android devices, respectively. The bank customer can learn about the app from the bank’s website where a link is usually provided to the app stores. Our apps give insights, help customers save money automatically, and help financial institutions understand their customers better.
This behind-the-scenes capability bodes especially well, because 52% of Millennials are using third-party apps from FinTech firms, instead of apps provided directly from banks, according to FICO’s report, “Millennial Banking Insights and Opportunities.” While we provide a third-party app, it’s white labeled, so banks and credit unions don’t have to give up those relationships.
Millennials are the fastest-growing generation today – and by 2030, there will be 78 million of them, compared to 56 million Baby Boomers, according to the FICO report. Millennials are beginning to earn more money, and accumulating more of the American Dream as they start to grow their families. It will become increasingly important for banks and credit unions to strengthen their relationships with Millennials, and finding ways now to do business with them – in the ways and manner they prefer – will become critical if institutions want to compete in the future.
Bankjoy delivers modern banking apps, including mobile banking, online banking, statements, and a banking API to banks and credit unions. Bankjoy’s apps feature built-in financial goal management to help people achieve savings goals while giving insight to financial institutions about what their customers are saving for. The company prides itself on creating beautiful products with simple navigation, modern look and feel, and world class user experiences shaped by talking to users. Bankjoy is a Y Combinator-backed company founded in 2015.
By Allison Murray, Executive Vice President, Business Development
Financial institutions really want us to be a partner in disruptive technology. I attend a lot of conferences in the disruptive space, and bankers as well as credit union executives tell me that they are experiencing interloping companies, such as Apple, Amazon and other players, trying to take away customers by offering a host of alternative financial services. They are entering these markets, but are causing great disruption and upheaval in the process.
We’re here to help banks and credit unions stay on the right side of invention and compete along with these disrupters rather than die out.
One of our innovative products is CheckAlt eChecks, a solution that leverages Check 21 technology rather than ACH, to provide faster and more transparent payments. eCheck payments sent via ACH can take up to three to five days to settle and are subject to strict item limits and thresholds set by the National Automated Clearing House Association.
However, eChecks sent via Check 21 are presented directly to the depository institution and offer fund availability in as few as 12 hours. Additionally, Check 21 eChecks are not governed by NACHA and therefore do not face the same restrictions – instead, custom item limits and thresholds can be set by the institution.
Our eCheck product is an API-based solution, which captures payment data from a front-end website and converts it to a digital front and back image of a check. One of the unique features of our product is its ability to include up to six additional lines of data, such as invoice numbers, customer IDs, transaction IDs, etc., in the memo field of the eCheck image. We also have the ability to include an electronic signature. These features are important because the check image will appear on the payor’s bank statement, as opposed to an alphanumeric non-descript line of data that would appear for an ACH transaction, so the payor (and the bank) will know exactly what the payment was for.
CheckAlt eChecks can be white-labeled by banks and credit unions and offered to business customers as a faster, more cost-effective payment alternative. Financial institutions can also use CheckAlt eChecks to collect loan, mortgage, credit card and other payments from their customers. Our eChecks can also be used by businesses directly.
We are very proud that clients are finding innovative ways to use our products. Indeed, Payoneer, a global leader in cross-border payments, is one company now using CheckAlt’s eCheck solution to improve the speed by which it credits funds between business owners and professionals who are sending and receiving payments.
Our approach not only means faster and less-expensive clearing, but also potentially fewer charge backs, simplified regulation and compliance. CheckAlt’s eCheck API easily integrates into existing websites, as well as desktop and mobile applications.
We truly believe Check 21 is the future of online payments. Our Check21 eCheck solution is just one more way we can be an innovative partner for financial institutions, helping banks and credit unions better compete by being on the forefront of invention.
By Robert MacMahon, Executive Vice President, Business Development & Channel Management
By now, practically every traditional bank or credit union understands that they have to find ways to either compete with or embrace FinTech to attract and keep customers.
But it’s not just about retail customers, particularly Millennials who have been bred to expect that technology should meet just about every demand at their fingertips.
FinTech firms also have their eye on business customers, including a plethora of alternative financial services startups backed by investors and venture capitalists, lending money to small businesses that traditional institutions turn down – small businesses who then leave those institutions for good.
How can a traditional bank or credit union compete? By being even more of a full-service institution and providing as many products and services to make commercial customers’ lives easier, particularly using the mobile channel.
This not only means offering mobile merchant services and treasury management solutions such as remote cash deposit services, Check 21 compliant check images, expedited payments and interconnected vaults at merchant locations, but also an increasing array of cloud-based solutions such as invoice presentment, advanced online payables, account management, taxes, payroll and other human resource solutions that more businesses – particularly small and micro-businesses like lawn care services and dog walkers – would love to have at the tip of their fingers.
Traditional banks and credit unions can even capitalize on the alternative lending movement – you name it – institutions can leverage any FinTech solution that a business customer could possibly need.
But how can institutions below the top 30 money center banks and large regionals — institutions with limited resources — offer solutions like that?
Let’s just look at one example at how challenging adopting FinTech solutions on a piecemeal basis can be for one of those institutions: offering a mobile app for remote deposit capture. It’s seemingly a relatively simple app to offer, but to get that solution to market, an institution typically has to rely on its core processor to allow a third-party app developer to connect its solution to the core system. However, most core vendors do not want to open up their systems in real time for posting those deposits because they don’t want the third-party assessing the core — that’s a problem.
Then an institution has to figure out how to handle potential security issues that remote deposit capture poses. For example, a fraudster could take a picture of a fake check, or take a picture and deposit a real check remotely, but then immediately try to cash the check at the institution’s branch or at another institution. That’s another challenge.
Suppose an institution decides to just work with a third-party app provider, but then there are issues importing images, and upgrades not being delivered. On top of that, an institution has so much already on its plate, that it can’t even imagine also handling sales and marketing of these third-party apps.
This example pales in comparison with what a bank or credit union has to do to provide solutions to commercial customers. While an institution’s niche may be primarily banking merchants and corporate entities, its focus may really be just on commercial lending. However, to increase the stickiness of commercial customers, institutions should strongly consider offering a much fuller array of products, and those solutions must be cloud-based and easily accessible via mobile.
Therein lies the most daunting challenge of all: contending with the financial industry’s own version of the Four Horsemen of the Apocalypse — operations, compliance, IT and sales. If institutions try to launch these solutions on their own, or in partnership with FinTech vendors for each separate solution, handling the due diligence for those Four Horsemen make such endeavors extremely tough.
That’s where we come in.
We like to call ourselves the “outsourced innovation lab,” a firm that can be a full-service outsourcing partner for institutions, helping them implement an ever-broadening array of solutions by a cadre of FinTech vendors that are either part of our portfolio of companies or trusted partners. Solutions that go well beyond the typical merchant and treasury management offerings – solutions that can make an institution truly full-service.
We want our financial institution clients to drive the implementation strategy. We sit down with our clients, taking the time to truly get a feel for where they want to go long term, which industry verticals fit well with their strategy, which target markets they want to focus on and which solutions they want to offer that we, our portfolio companies, or partners can then build out.
We also like to call ourselves a concierge service, because we are experts in helping our clients implement solutions while keeping the necessary due diligence of those Four Horsemen – operations, compliance, IT and sales.
We not only have partners that can produce either white-label off-the-shelf solutions or build customized solutions, but we can also go far beyond typical marketing and training support: We have experts who are just a phone call away from helping sales personnel answer complicated questions posed by prospects in the field, or the experts can even accompany them on the sales call to help close the deal.
We have a client-oriented approach: it’s all about service and support to institutions that have limited resources and may not want complicated systems. Many of our client institutions don’t serve large or medium companies, but instead focus on sole proprietors or outfits with just one or two principals, and they really only need low cost-of-entry, simplified solutions. They might not even need co-branding – perhaps they just prefer something right out of the box to satisfy 75% of their business needs.
The last piece of our business model: We aim to provide our clients with a predictable margin for each solution below what a company would have to pay in the open market from a provider directly for that solution.
We aim to give our clients an interest-free income revenue stream, in a way that is easily quantifiable. With our concierge outsourcing services, our clients won’t have to offer FinTech solutions as loss leaders – they won’t have to try to fight for something by cutting the price down to bare minimum or sell it at a loss.
We aim to help our clients successfully compete in the new world so they can attract and retain more business customers, in ways that can also greatly boost their own bottom line, without having to add staff or dedicate already thin resources.