If an institution imposed a check-cashing fee of $2.00 that would be implemented on members' accounts that do not have an aggregate of $250 in Share, Share Draft, Vacation and/or Christmas Club or IRA accounts -- could they advertise their checking account as "free?"

Commentary for Sec. 230.4(b)(4)-2 -- "Fees for services offered to account and nonaccount holders alike, such as travelers checks and wire transfers (even if diferent amounts are charged to account and nonaccount holders)"

Would cashing checks for a fee fall under this exception? Any opinions on this would be appreciated.

The act of "check cashing" is not directly related to maintaining a checking account and therefor would not impact the free status.

Thank you for your feedback!

One caveat - while Reg DD may view the account as "free", since many financial institutions do NOT charge their own customers for cashing a check, then your customers may feel mislead. Are you charging them to cash a check on the account with the Credit Union, or are you charging them if they want to cash a check from the outside?

Literal compliance with Reg DD may make the regulators happy, but you should still take a look at it from the customer perspective and try to make sure your advertising does not leave someone with the feeling that they've been "had."

Bonnie, would it look something like this.

LOL!!!!!

Is that lots of love or laughing out loud? Here is that check cashing fee question again. Anyone got a definitive answer?

Actually - it would be ROTFLOL - Rolling on the Floor Laughing Out Loud, but seeing as I just got this outfit back from the cleaners, we'll have to leave it at LOL!

And as far as I know, there is no definitive answer, but I understand some of the larger national banks have started to charge a fee for non-customers.

They are charging a fee, but could they just outright refuse to cash the noncustomers on-us checks?

"just outright refuse to cash the noncustomers on-us checks?"

So Carl Customer issues a check drawn on your bank/CU to Jane Doe who comes in to cash it and you are going to refuse payment because Jane is not also a customer? Sounds like wrongful dishonor unless there is an ID, endorsement or available funds problem.

Sometimes Andy I wonder about you. Funny!