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Latest Compliance - Dormant Accounts Topics

Debit Card and Online Banking Inactivity Fees

01/31/2016

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.

Notification When Acct. Changes to Dormant?

10/18/2015

I​​s it mandatory for a bank to send notices when an account status changes from active to dormant? ​W​e send notices when the account status changes from dormant to active but not the other way.

Dormant Status for Health Savings Accounts

08/16/2015

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?

Laws On Changing Monthly Fee On Dormant Accounts

09/01/2014

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?

Dealing with Dormant Accounts

08/09/2010

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.

Advance Notice To Raise Fees?

02/10/2003

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?

Regulatory Requirements For Dormant Accounts

07/15/2002

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?

Problems for the Future

01/01/2000

In planning your compliance program strategies for the future - or at least the next several years - there are issues that we can see coming.

Most Popular Compliance Content

Opening Online Acct. & Funding w/ACH Debits

06/16/2019

Our digital channel team would greatly appreciate your comments and confirmation of our understanding in order to comply with online account opening and funding for new clients with ACH Debits and the ability to hold funds. The questions below relate to an online account opening process for new clients. After completing the online application, approved clients have the option to fund their new account with funds from an external source – an account they hold at another bank - via an ACH Debit and we are the ODFI. 1. Can we place a hold on the initial funds received as an ACH Debit? Our understanding is “yes” because: · an ACH debit does not fall under the definition of an electronic payment under Reg. CC (II.Section229.2 Definitions (p)) Electronic Payment, which imposes no availability requirement, and we are free to hold the funds for a period that we determine. Restricting access to those funds would be reasonable to allow for the debit entry to reach the RDFI and be returned to our bank, the ODFI, if there is a problem. · We are not receiving an ACH credit as we are the ODFI of the ACH debit, and NACHA has no say in when we credit the new account, so there would be no violation of NACHA rules.</ul> 2. Would we be required to provide a hold notice to our online account applicant of the delay in availability or a notice at the time the external funding option is selected that the funds may not be credited to the account for “2-3 days”, or available for “2-3 days” suffice? Our understanding is: · a notice that indicates funds may not be available for x days at the time the customer selects the external funding option and submits their authorization should suffice as it becomes part of our agreement when the customer selects that funding option. · Reg. CC does not impose an availability requirement for ACH Debit transactions, so no Reg. CC hold notice is required. 3. Would our Reg. CC Policy – Funds Availability Notice, need to be updated to refer to availability from ACH Debit transactions? · Model language is silent in this regard, any recommendations or suggestions are welcome.

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