Here is the scenario - A bank opens a trust account with a Certificate of Deposit in May. Annually, the trust department charges the annual trust fee. When the annual fee was charged against this trust client, the CD was reduced by the amount of the annual fee. Can a bank do this? Our concensus was that the trust client should of been billed not reducing the CD amount.
Does anyone have an opinion on this? Is it a violation of Reg D? Thanks!