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Banks affected by the CFPB’s “Surprise fees” guidance

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Question: 
What financial institutions are affected by the CFPB’s guidance on surprise overdraft and depositor fees?
Answer: 

The Bureau’s Bulletin on surprise depositor fees was issued to “notify regulated entities how the Bureau intends to exercise its enforcement and supervisory authorities on this issue.” The Bulletin directly affects banks and credit unions with total assets over $10 billion, which the Bureau examines for compliance with consumer protection laws. Because the Fed, FDIC, OCC, and NCUA could take the same viewpoint on the topic, all banks and credit unions could eventually be affected. The Consumer Financial Protection Circular on Surprise Overdraft Fee Assessment is more widely accepted by regulators and presents issues that all banks and credit unions may need to deal with.

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First published on 04/21/2024

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