Banking Spectrum - What's New?

Financial institutions are required to report a deposit account as abandoned property if there has been no activity in the account or written contact from the customer evidencing that the customer is aware of the account for a period of three years. Published guidance from the Comptroller never specifically addressed whether receipt of an email from a customer or other electronic activity constituted sufficient written contact from the customer to reset the dormancy period.

New regulations state that certain electronic activity does constitute sufficient contact to reset the dormancy period. The electronic activity cited in the regulation is the following:

(1) the receipt of electronic mail (email) communication from the entitled account holder of the property that matches the registered email address on record; or

(2) evidence that the entitled account holder has accessed their personal account through the electronic method made available by the holder of the property, including but not limited to, a website, mobile application, or any other reasonable electronic method.

Read more in the Abandoned Property chapter of The Gold Book