In reviewing the Call Report line item changes for institutions > $1 B in total assets,
"Consumer Account Periodic Maintenance Charges Levied On Thos Transaction Account & Nontransaction Savings Account Deposit Products Intended Primarily For Individuals For Personal, Household, Or Family Use [Memo Item 15(b)] - for deposit account products intended, marketed, or presented to the public primarily for individuals for personal, household, or family use, report the amount of service charges for account holders' maintenance of their deposit accounts with the reporting institution (often labeled "monthly maintenance charges"), including charges resulting from the account owners' failure to maintain specified minimum deposit balances or meet other requirements (e.g., requirements related to transacting and purchasing other services), as well as fees for transactional activity in excess of specified limits for an account and recurring fees not subject to waiver.
Recurring fees not subject to waiver include fixed monthly or other periodic charges levied against a consumer deposit account that the account owner cannot avoid under any circumstances, including, for example, by maintaining other deposit or loan accounts with the institution, maintaining a minimum deposit balance, or engaging in a specified level of account activity (such as the number of debit card transactions) during a month or other period.
As always the CFPB is not specific and I was wondering how you determine what is a maintenance charge, transactional charge or recurring charge. Do you have sample verbiage in your disclosures that distinguish the difference and how to you total each charge for the call report?
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The opinions expressed are mine and do not necessarily reflect those of my employer.