07/28/2024
When is the CFPB likely to issue a final regulation making banks over
$10 billion in assets cut their overdraft fees back to a breakeven amount or start
treating overdrafts as extensions of open-end credit subject to Regulation Z?
07/21/2024
Our institution has chosen not to charge NSF fees on ANY ATM/debit
card transactions whether they are one time or recurring. Having said that, if we
are in an APSN situation at end of day and the account is now overdrawn, we
DO charge an Overdraft Fee (even if the only item causing the overdrawn
balance is the ATM/Debit card transaction). Would this be perceived at
UDAP/UDAAP? Additionally, both NSF fees and OD fees are the same amount.
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.
06/21/2020
Our bank has limited the number of overdrafts an employee may have in a rolling 11 month period. Management now would like to treat employee like other bank depositors and eliminate the limit. Are there any compliance concerns with this action? My initial comment was that employees of a bank should be held to a higher standard as the general public is entrusting their funds in the integrity of the bank's staff. Thoughts?
12/22/2019
Can a POS transaction be returned for insufficient funds and charged an overdraft fee if our bank does not offer overdraft protection? Would there
be a benefit for a customer to "Opt In" if we continue to not offer overdraft protection?
11/24/2019
If a personal checking is protected by a second personal checking (sweep) for the purpose of Overdraft Protection should the child account reflect the
available balance of both accounts?
11/05/2017
We have just started with e-statements. Our overdraft protection statements have the same account number as the checking account it is attached to and are created at the same time as checking accounts. Are the Reg E and Z disclosures that we provide with each ODP statement going to be required on every ODP e-statement? Is that also true for the checking statements for Reg E?
12/04/2016
Is there a regulatory limit on the number of overdraft charges that can be applied in one business day?
11/13/2016
May an advertisement mention the term “free” with respect to a financial institution’s overdraft services?
05/25/2015
On a reserve line of credit tied to a DDA account. Is it necessary to provide a monthly statement when there is no activity? Zero balance, no advance nothing owing.