On May 18, 2016, five federal banking agencies—the Board of Governors of the Federal Reserve System (“Board”), the Consumer Financial Protection Bureau (“CFPB”), the Federal Deposit Insurance Corporation (“FDIC”), the National Credit Union Administration (“NCUA”), and the Office of the Comptroller of the Currency (“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.

Under the Guidance, a credit discrepancy arises when a customer makes a deposit to a deposit account and the amount that the financial institution credits to that account differs from the total of the items tendered for deposit. For example, a customer may tender $110 for deposit, but the financial institution will credit only $100 because, for example, the deposit slip incorrectly says $100. Common reasons for credit discrepancies include customer error or teller error in completing deposit slips, teller or back-office error in coding deposit transactions, and poor image capture. Per the Guidance, a credit discrepancy is a “detriment to the consumer,” and it “benefits the financial institution, if not appropriately remedied.”