We are receiving a significant number of computer-generated, form letters from Cushion, a fintech in San Francisco, requesting refunds of fees (generally overdraft fees). In researching Cushion, I have found that a consumer pays an annual fee and provides the company with access to their bank accounts via online banking. Cushion then scans the customer's accounts looking for fees. If it finds any fees, it generates a letter requesting the fees be refunded, citing difficulties during the COVID pandemic. We are handling these requests according to our policy, but the volume of requests has significantly increased and we are receiving as many as 50 per day. I would like to know if other institutions have reported receiving these third-party refund requests from and how they are dealing with them. In addition, have you heard any thing about these types of services from the regulatory agencies' perspective.
Can a bank require employees to have an account and services so that they can help customers with functionality? We do not require them to have their payroll deposited at our institution.
In a webinar I attended earlier this year on Levies it stated, “Levy proceeds must not be reduced by any fee charged by the bank for processing the levy.” Would this rule apply to levies at the state level such as from the State Comptroller office or for Child Support?
When increasing a fee to drill a safety deposit box, do all customers need to be notified ahead of time?
On a down payment assistance 2nd mortgage, can a lender charge $40 application fee to the borrower?
I have searched the site for information on advertising. I am a new compliance officer and need help. My bank is wanting to give money towards mortgage loan closing costs. I am not sure of how to check what is needed for advertisements and if there are any IRS requirements.
Is there a regulatory/legal preclusion for charging a customer (consumer or commercial) a return wire fee for domestic or international wires? If a preclusion exists, what law/regulation is applicable?
We have a customer who signed & opted into ODP when he first opened the account in September. After the 45-day qualification period, it was found that his account was eligible for ODP so we activated the ODP on his account. A teller at his branch, however, took a request from him to revoke ODP on his account in late November. This was not relayed to the appropriate staff and the change did not get made on his account. His TV bill, which is an authorized monthly payment, came through on his account as a POS debit while he was already a couple dollars negative. It should've been declined due to NSF and him previously revoking ODP. We've since made the appropriate changes on his account to revoke ODP on his account and we've reversed all the fees he shouldn't have been charged, but the customer is saying he is not going to pay for it, and that the bank is responsible for it.
My question is - is the bank responsible for it?
Can a bank order a credit report for a customer without an extension of credit or opening an account and collect from them the pass-through fee?
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.