No ODP. Still Disclose the OD & NSF Fees?

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Question:

The new rules for ODP state that monthly statements must disclose total OD and NSF fees. Is this true only if there is an ODP in place, or must it be put in place for ALL accounts and ALL banks?

Answer:

Disclosing the total NSF and OD fees for both the statement period and YTD are requirements only for those accounts in which the institution promotes ODPs. However, many of those banks may find that it is operationally easier and stronger risk management to just provide the disclosure for all accounts.

All banks must begin to segregate fees on the statement that are for payment of items that create a negative balance from fees on the statement that are for returning an item as NSF. They must also make sure their initial TIS disclosure identifies the ways the account could become overdrawn. They must also make sure their disclosure of account related fees as part of the TIS disclosure also segregates OD fees from NSF fees and uses the same terminology as will be used on the statements.

First published on BankersOnline.com 6/05/06