We implemented a minimum balance fee on some of our accounts as of March 1st. We provided the 30 day notice to existing clients and changed our account opening TISA's. I'm finally circling back to ensure that the verbiage being used when the fee actually posts is the same as what was previously disclosed.
In two instances the system says "Service charge" but the fee has been disclosed in all places as "minimum balance fee" I don't know why it ended up this way (still researching with operations) and I know I need to fix it asap, my question is this - am I required to go back and reimburse consumers who were charged a minimum balance fee when it said "service charge" on their statement? It's only been a few months, clearly an oversight on our part, TISA does not say anything about reimbursements, willful violation, etc (like Reg Z does). I'm not trying to cover anything up, I don't believe this has been a detriment to any customer, refunding fees in this tight economy is difficult, but I also want to do the right thing. any insight?