Dormant Account Handling Policy

Purpose

This policy establishes the Bank's framework for the identification, classification, management, and eventual disposition of dormant accounts. It ensures compliance with applicable regulatory requirements regarding unclaimed property and dormant account reporting, while safeguarding the interests of account holders.

Scope

This policy applies to all deposit accounts (current, savings, and fixed deposit) held by individual and corporate clients across all branches and jurisdictions where the Bank operates.

Definitions

Term	Definition
Inactive Account	An account with no client-initiated transactions (debit or credit, excluding Bank-initiated entries such as fees and interest) for a period of twelve (12) consecutive months.
Dormant Account	An account with no client-initiated transactions for a period of twenty-four (24) consecutive months.
Unclaimed Account	A dormant account where the Bank has been unable to contact the account holder for a period of sixty (60) consecutive months (five years).

Classification Process

Step 1: Identification

The Core Banking System (CBS) automatically flags accounts that meet the inactivity criteria through a monthly batch process run on the first business day of each month.
The Account Management team reviews the flagged accounts and confirms the classification status.
Accounts with standing orders, direct debits, or scheduled transfers that continue to execute are excluded from dormancy classification.

Step 2: Client Notification — Inactive Accounts

When an account is classified as Inactive (12 months of no activity), the Bank issues a first notification to the account holder via registered mail and email (if available), advising of the inactivity status and requesting contact.
A second notification is issued at the 18-month mark if no response has been received.
All notification attempts are documented in the CBS account notes.

Step 3: Reclassification to Dormant

If the account holder does not respond or initiate any transactions within 24 months, the account is reclassified as Dormant.
Upon reclassification, the following restrictions are applied automatically by CBS:

All debit transactions are blocked (debit freeze).
Online and mobile banking access is suspended.
Debit card access is deactivated.
Credit transactions (incoming transfers, interest postings) continue to be accepted.

Step 4: Dormant Account Management

Dormant accounts are segregated in the Bank's books and reported separately in the dormant accounts register.
The Account Management team conducts a semi-annual review of all dormant accounts to identify opportunities for reactivation or accounts approaching escheatment thresholds.
Interest continues to accrue on dormant savings and fixed deposit accounts in accordance with the applicable product terms.
Account maintenance fees may continue to be deducted, subject to the Bank's fee schedule and applicable regulatory restrictions on charging dormant accounts.

Reactivation

A dormant account may be reactivated upon the account holder's request, subject to satisfactory identity verification and an updated KYC review.
The account holder must visit a branch in person with valid photo identification, or complete the Bank's remote reactivation process with enhanced authentication.
The Compliance team reviews the reactivation request for any suspicious activity indicators before the account restrictions are lifted.
Upon successful reactivation, all channel access and transactional capabilities are restored within one (1) business day.

Escheatment and Unclaimed Accounts

Accounts that remain dormant for sixty (60) months (five years) and where the Bank has been unable to establish contact with the account holder despite reasonable efforts are classified as Unclaimed.
Unclaimed account balances are reported to the relevant regulatory authority (Central Bank or designated government agency) in accordance with local escheatment laws.
Where required by law, unclaimed balances are transferred to the designated government escheatment fund. The Bank retains records of transferred balances for a minimum of fifteen (15) years.
Account holders (or their legal representatives) may claim escheated funds by contacting the Bank or the relevant government agency, subject to satisfactory identity verification and legal documentation.

Regulatory Reporting

The Bank submits quarterly dormant account reports to the Central Bank, detailing the number and aggregate balances of inactive, dormant, and unclaimed accounts. The Head of Account Management is responsible for ensuring the accuracy and timeliness of these reports.