Our Retail Division is getting very creative in coming up with fees that we have not charged in the past. I understand that dormant/inactivity fees are defined at the State level and are allowed on accounts advertised as "free." Would the same hold true for debit card inactivity and/or online banking inactivity fees? Would these fees be allowed on "free" accounts if properly disclosed? I have the same question for return mail fees.
Is it mandatory for a bank to send notices when an account status changes from active to dormant? We send notices when the account status changes from dormant to active but not the other way.
Can a Health Savings Account be put into dormant status? Can the account then be closed? If we do close the account after the statute of time, if there are any monies available how are those funds to be distributed and to whom?
I have two questions in regards to dormant accounts. We consider accounts to be dormant after 24 months of inactivity.
1.Are there varying state laws when it comes to the ability to charge a monthly fee on dormant accounts?
2.If we have a customer that has multiple accounts and they are like titled, same address, can we transfer the funds to an associated active bank account if we disclose this to our clients via some manner of electronic communication?
Information on dormant accounts. Loan is Bankrupt and small amount in a DDA account. How long till you can do something with dormant accounts?
We have several dormant accounts with less than one dollar in them. Should we charge each account a regular monthly service charge which would be equal to the balance, then close it out, or should we send everyone a money order for the amount? That way, if it comes back to us, we'll escheat it and all others we get back, to the state.
Is it a requirement to send privacy notices to dormant DDA accounts?
It we increase our fees on stop payments, dormant accounts, and add a daily overdraft fee, do we need to send our existing customers advance notification of the fee increases?
Where in the regs do you go to find more information on dormant accounts? Example: can you close a dormant or inactive account with a very small balance, and what fees can you charge on a dormant or inactive account?
In planning your compliance program strategies for the future - or at least the next several years - there are issues that we can see coming.