IBA Compliance Connection

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We just completed a data bureau conversion that eliminated savings and loan passbooks. Now that we are not using the passbook system, are we required to provide receipts for deposits not made in person? Or can we notify customers that we plan to discontinue sending receipts and that they can review their deposits by accessing their accounts online? Our deposit agreements do not require receipts, but I want to confirm whether any state law applies.

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We are not aware of any Illinois law that requires financial institutions to issue receipts for deposits not made in person. If your account agreements do not require receipts, you may discontinue issuing them. However, we recommend that you proceed with your plan to provide your customers with advance notice of the change. In addition, we note that Regulation E still requires receipts for deposits made at electronic terminals, such as ATMs.

For resources related to our guidance, please see:

  • Regulation E, 12 CFR 1005.9 (“Except as provided in paragraph (e) of this section, a financial institution shall make a receipt available to a consumer at the time the consumer initiates an electronic fund transfer at an electronic terminal.”)