Most Popular Operations Content
Handling creditors of deceased customer
04/23/2023
If a creditor inquires about a debt owed how would it be handled with the Privacy Act?
Who registers with FinCEN for BOSS
04/23/2023
Are there exemptions?
DeFi Explained
04/23/2023
What is DeFi?
OD Fees, Authorized Positive
04/23/2023
When reading the Consumer Financial Protection Circular 2022-06, we are trying to understand if banks are not allowed to charge an overdraft fee on a transaction that was authorized positive and settled negative, regardless if they had OD privilege or not? In the Circular 2022-06, it states that overdraft fees can be deemed unfair acts or practices even when the financial institution complies with federal regulations including Regs Z and E.
Charging a fee, for charging a fee
04/23/2023
While the Fed has revoked Reg D, when it comes to excessive withdrawals individual banks are still able to charge fees after a predefined number of debits or withdrawals. The question I have is when a bank charges a fee, should that fee be counted toward that withdrawal number? I am concerned that this is a UDAAP risk.