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3rd Party Refund Requests for OD Fees

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Question: 
We are receiving a significant number of computer-generated, form letters from Cushion, a fintech in San Francisco, requesting refunds of fees (generally overdraft fees). In researching Cushion, I have found that a consumer pays an annual fee and provides the company with access to their bank accounts via online banking. Cushion then scans the customer's accounts looking for fees. If it finds any fees, it generates a letter requesting the fees be refunded, citing difficulties during the COVID pandemic. We are handling these requests according to our policy, but the volume of requests has significantly increased and we are receiving as many as 50 per day. I would like to know if other institutions have reported receiving these third-party refund requests from and how they are dealing with them. In addition, have you heard any thing about these types of services from the regulatory agencies' perspective.
Answer: 

If you are charging fees for services that you have not properly disclosed or charging more than you have disclosed, then you have bigger issues. Otherwise, I would be throwing these in the trash. You are under no obligation to take any action on them.

First published on 05/02/2021

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