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#740680 - 05/25/07 05:19 PM Reg DD and Fees on Statements
Reed Offline
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Reed
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Should check copy and statement copy fees be included in "covered fees" that are disclosed on statements?

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#740694 - 05/25/07 05:28 PM Re: Reg DD and Fees on Statements Reed
rlcarey Online
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What are "covered fees"?
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#740805 - 05/25/07 06:30 PM Re: Reg DD and Fees on Statements rlcarey
Reed Offline
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"Section 230.4...
(b)(4) Fees
1. Covered fees. The following are types of fees that must be
disclosed:
iv. Fees for special services, such as stop-payment fees, fees for balance inquiries or verification of deposits, fees associated with checks returned unpaid, and fees for regularly sending to consumers checks that otherwise would be held by the institution"


Just wondering if check copy fees qualifed

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#740815 - 05/25/07 06:37 PM Re: Reg DD and Fees on Statements Reed
John Burnett Offline
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Those "covered fees" are the ones that have to be disclosed in account disclosures under section 230.4. That section does not affect what has to be printed on statements. Correction: If the fee has to be disclosed under 230.4, it also has to be disclosed on statements.

I don't believe that copies of checks or statements are fees that need to be disclosed, in any event. They aren't fees necessary for the operation of the account. Notice a key word in the 230.4 language quoted above: "regularly."

There's no requirement that you describe check copy or statement copy fees when you charge them to a customer's account. A simple miscellaneous debit suffices.
Last edited by John Burnett; 05/25/07 08:08 PM.
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#740984 - 05/25/07 07:50 PM Re: Reg DD and Fees on Statements John Burnett
Reed Offline
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Originally Posted By: John Burnett
Those "covered fees" are the ones that have to be disclosed in account disclosures under section 230.4. That section does not affect what has to be printed on statements.


Sec. 230.6 Periodic statement disclosures.
a) General rule. If a depository institution mails or delivers a periodic statement, the statement shall include the following disclosures:
(3) Fees imposed. Fees required to be disclosed under Sec. 230.4(b)(4) of this part that were debited to the account during the statement period. The fees shall be itemized by type and dollar amounts.

??????

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#741052 - 05/25/07 08:10 PM Re: Reg DD and Fees on Statements Reed
John Burnett Offline
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Right you are, Lakshmi. I misspoke (or mistyped). I've corrected my post above. I would not include copies of checks or copies of statements in the list of fees you have to disclose under either section 230.4 or section 230.6.
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#741098 - 05/25/07 08:26 PM Re: Reg DD and Fees on Statements John Burnett
Reed Offline
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Ok, thanks.

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