Answer:
You are responsible for those fees and other costs imposed by your bank only. That includes any fees for the EFT and any fees that would not have been imposed if the error had not occurred. You are under no regulatory requirement to refund fees imposed by a third party (unless those fees were charged by unauthorized EFT to your customer's account). For example, if an unauthorized ATM withdrawal caused your bank to bounce your customer's check for insufficient funds, you'd be obliged to refund your check return fee and any other fees your bank imposed. But if the local grocery store charges your customer a $20 fee to get his check-cashing privileges back, you aren't responsible for reimbursing your customer for that fee (although you certainly may choose to do so). Check to see if you have agreed to cover third-party fees in your account disclosures.
First published on BankersOnline.com 12/10/07
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