I would not suggest that a bank adopt changes to its disclosures based purportedly on one examiner's opinion. I happen to feel that the industry must adopt one acceptable lexicon for overdraft services, fees of all kinds, and balance types. Customers should be able to rely on uniformity when they get disclosures about uncollected or unavailable funds, overdraft fees, NSF fees, and so on. If the industry can't or won't do it, the Bureau should do it and make the industry (and examiners) adhere to it.
End of rant.
John S Burnett