Our bank offers savings club accounts to allow customer to save up for holidays or vacations. For the period of a year, funds are regularly transferred from the customer's checking account to the savings club account. At the end of the year period, interest that accrued during the year is posted and the funds are transferred back to the checking account. An annual statement is generated to show the interest posted to the account.

We have a question about Reg DD statement requirements in relation to savings clubs.

A customer withdrew funds from the account at the same time that the annual transfer from the account occurred, overdrawing the account and resulting in an NSF fee. The NSF fee occurred the day after the statement was generated and so was not reflected in the annual statement.

Per Reg DD is the bank required to send a statement showing the NSF fee, or is there any exception in the regulation for savings club accounts?

Thank you

The time and energy being expended on scratching your head over this cannot be more valuable than one overdraft fee. Waive the fee and move on. Sounds like you have an operational issue, and this was the bank's fault anyway.

We are not requesting information to determine whether we should refund the customer's fee. We are requesting information to determine whether we have a regulatory risk and whether we need to make system changes to turn on statements or send overdraft notices for these types of accounts.

Thank you

I have never seen a savings club account that provided for overdraft fees, as the bank usually controls any withdrawals. You need to read your account agreement to see if imposing an overdraft fee is even possible.

There are no requirements to even provide a periodic statement, if the account is not subject to Regulation E.

OFFICIAL INTERPRETATION OF SECTION
Section 1030.6--Periodic Statement Disclosures
(a) General rule.

1. General. Institutions are not required to provide periodic statements.