Fee Summary At The End of Checking Statement

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Question:

My question is about the fee summary at the end of a checking statement. The Total for this period column would be for that specific statement cycle. The Total Year-to-Date column is where my question comes. Assuming that an account had NSF/OD from 12/18/12 thru 12/28/2012 and the statement cycle was 12/18/2012-1/17/2013. The first statement printed in 2013; the Total Year-to Date field should be zero, correct; however the Total for this Period would include the fees for the entire statement cycle. From a compliance perspective, the Total Year-to-Date column would be missing any fees that happened between 12/18/2012-12/31/2012 correct?

Answer:

Official Interpretations of this section.

Section 1030.11--Additional Disclosures Regarding the Payment of Overdrafts

(a) Disclosure of total fees on periodic statements.

(a)(1) General.

5. Totals for the calendar year to date. Some institutions' statement periods do not coincide with the calendar month. In such cases, the institution may disclose a calendar year-to-date total by aggregating fees for 12 monthly cycles, starting with the period that begins during January and finishing with the period that begins during December. For example, if statement periods begin on the 10th day of each month, the statement covering December 10, 2006 through January 9, 2007 may disclose the year-to-date total for fees imposed from January 10, 2006 through January 9, 2007. Alternatively, the institution could provide a statement for the cycle ending January 9, 2007 showing the year-to-date total for fees imposed January 1, 2006 through December 31, 2006.

First published on BankersOnline.com 6/24/13