FWIW - I concur with your assessment. I can also tell you from personal experience, this is not an area in which you want to get aggressive. The States consider this money due to them. I was in one State where we were inappropriately assessing service charges on inactive accounts and we had to pay the State a fine in the mid-six figures and this was back in the 80's. I wouldn't even cross the line on a "case-by-case" basis. If they deem that you have violated this portion of the law, they can make you pay them all the service charges you have ever assessed on dormant accounts. That is what happened to us and the settlement was a negotiated settlement.
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