If we chose to temporarily reduce the dollar amount of OD fees, would we have to disclose to customers when the fee amount returned to the normal price?

I think reducing the number maximum number of fees charged would be a simpler solution.

A depository institution shall give advance notice to affected consumers of any change in a term required to be disclosed under Sec. 1030.4(b) of this part if the change may reduce the annual percentage yield or adversely affect the consumer.

I am not aware of any notice required if you forego certain fees for a period of time.

If you decide to waive those fees temporarily for the current crisis, be aware that it may be a long while before things are back to whatever becomes our new "normal." I imagine you plan to inform your customers of the waiver. I recommend that you alert them on the way out of the crisis with a simple statement to the effect that the "temporary waiver of overdraft fees during the COVID-19 emergency will end on [date]. Give them some lead time. Thirty days seems to be agreed upon as a reasonable advance notice period.

Also remember that Regulation B considers an overdraft to be an extension of credit even if Regulation Z does not consider it a finance charge. Any changes to fees should be uniform for all customers.

I had a client that tried charging lower OD fees for a "college account" that was only open to customers under the age of 24. That resulted in a fair lending finding since they charged a different fee for credit based on age.

Yeah, you can only give cheaper credit to old f@rts like me or in special lending programs.