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#1990812 - 01/23/15 09:13 PM Charge-Off and Disclosure of Fee
compliancegeek Offline
100 Club
Joined: Jul 2004
Posts: 129
Midwest
Two questions: 1. Would we be able to assess a collection or charge-off fee and add it to the balance when we close an account with a negative balance that may or may not contain fees related to overdrafts/NSF items (fees to collect fees)? 2. If so, is this a fee that should be disclosed on an “Other Fees” schedule where we typically disclose things like overdraft fees, statement copy fees, etc.? Is there anything else that I'm not thinking about - such as UDAAP? Thanks!

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#1990815 - 01/23/15 09:14 PM Re: Charge-Off and Disclosure of Fee compliancegeek
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,388
Galveston, TX
1. Allowable fees are a State law issue.

2. Assessing undisclosed fees are never a good idea.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1990834 - 01/23/15 09:42 PM Re: Charge-Off and Disclosure of Fee compliancegeek
compliancegeek Offline
100 Club
Joined: Jul 2004
Posts: 129
Midwest
Thank you!

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