Reg DD Compliance – Overdraft Fees & Return Fees
Answer by Randy Carey, BOL Guru Guru Bio
Question:
We use our discretion to pay or return items presented against a checking account at the end of each business day. We charge an overdraft fee for each item paid, and a return fee for each item that is returned. Our ATM/debit cards are "daily dollar limit"...the ACH debit for all card transactions is always paid and an overdraft fee is assessed. Do we need to do anything to comply with the changes to Reg DD other than to include the month-to-date and year-to-date fees on our checking account statements?
Answer:
Not currently, but you will want to pay close attention to the recent Regulation E amendments. As of July 1, 2010, unless the customer opts-in for overdraft coverage, you will no longer be able to charge overdraft fees for these transactions.
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