Reg D limits savings account automated/ACH type transactions to six per month. In the case of NSF ACH items returned, does transaction mean transactions attempted or transactions completed? Do items returned not paid (NSF/stop payment) count against the six transactions?
I have seen a number of hold notices come across my desk that are for amounts under $5000 that have exceptions. Is this a normal practice or should deposits under $5000 be a case by case situation?
Is there a provision in Reg CC (or any other regulation) that gives a depositing bank the right to redeposit an item that was returned for NSF?
If a loan customer's automatic payment from another bank is returned to us NSF can we charge a returned item fee to the loan and then add on a late charge if the loan payment becomes delinquent?
Can we charge a fee for an overdraft or NSF check and interest on the overdraft balance?
My recent return to banking, in particular compliance, has been welcomed by changes in the last 3.5 years. The ODP changes are the first hurdle at my bank, as they originally believed the changes did not affect them. My understanding is if their practice has been to charge an NSF fee regardless of pay or return, this is no longer appropriate to only indicate on the statement NSF fees. Paying an NSF actually creates an overdraft, and the fee should be clearly described as such. Obviously, if I'm right, our forms companies should be happy as we will be working behind the curve to get in compliance with the new amendment. Also outside of regulators writing us up, what are the possible ramifications of not being in compliance by 7/1/06?
We don't offer/promote ODP on commercial accounts, however we do occasionally pay on NSF. My question is if we have an overdraft and we charged them overdraft fees and they did not resolve the overdraft for a month can we charge interest on that overdraft?
If we do not advertise payments on overdraft, do we still have to make changes on our statements to include fees for returned and paid items?
The new rules for ODP state that monthly statements must disclose total OD and NSF fees. Is this true only if there is an ODP in place, or must it be put in place for ALL accounts and ALL banks?
I have a question about sending an adverse action notice to a minor. The minor was in to open up a free checking account with her mother but was denied due to the mother having NSF activity. Do we just send a notice to the mother or is it required to send one to the daughter as well?