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Charging a fee, for charging a fee

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Question: 
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.
Answer: 

If you have to ask, it usually is. If you do not understand how it works by reading your detailed fee description, how will your customer.

First published on 04/23/2023

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