No one on the IBA Compliance Advisory Committee had experiences with deposit reserve accounts. However, one committee member did note that her bank had budgeted for debit card losses as part of its annual budgeting process for 2016. This was the first year that the bank budgeted for these losses. The bank does not set aside funds, but simply budgets for projected losses. The loss projection was based on the compliance department’s annual board report on debit card fraud losses, which for this bank had increased significantly, to $10,000, in 2015.
Should a bank maintain a deposit reserve account similar to a loan loss reserve, but for debit card losses, kiting, bad checks, etc.?
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