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Question & Answer
Question: Our disclosures state that we have no fees for telephone transfers but are silent on ACH fees. We do not actually charge for either service. Is there any problem with having one explicit statement and then being silent about another?
Answer: No, although it could cause some customers to ask questions. Regulation E requires you to disclose fees that your charge. There is no requirement that you list fees that you do not charge. Often stating that you do not charge a fee can be a selling point - a way of pointing out how your bank's service fees are better (lower) than the competition. There will be times when the marketing staff wants to say something positive and this is one thing that can be included.
As for consistency, there is no requirement that you be consistent in stating that there is no fee or simply not listing a service for which there is no fee. Your decisions on this should be driven by what customers understand and what they ask about. Use the disclosures to answer common questions. If customers frequently ask about ACH fees, go ahead and put in the "no charge" disclosure. Otherwise, you are free to leave it out.
Copyright © 1998 Compliance Action. Originally appeared in Compliance Action, Vol. 3, No. 7, 5/98
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