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#1139069 - 03/03/09 06:39 PM Reg DD Disclosing Fees
~MunQue~ Offline
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~MunQue~
Joined: Jul 2006
Posts: 718
HERE! I'm here!
On our disclosures we state an NSF fee for if an account falls insufficient. I have an auditor telling me I have to list every way that the account can fall NSF, i.e, check, ACH, POS...
She is saying it's stated in 230.4 (b)(4). It does say to put the conditions for imposing fees, but I always thought that your account falling NSF was the condition that would cause the fee to be imposed.

Does anyone else do this, or have any opinions?

I appreciate your input.
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The higher up the monkey climbs, the more you see of it's behind.


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#1139110 - 03/03/09 07:27 PM Re: Reg DD Disclosing Fees ~MunQue~
Steve Doty Offline
100 Club
Joined: Mar 2007
Posts: 137
Nebraska
An exhaustive list is not required. It is sufficient to state, as applicable [Commetary to 230.4(b)(4)#5-page 7464]

"An overdraft fee applies to overdrafts created by check, in-person withdrawl or other electronic means."

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#1139113 - 03/03/09 07:30 PM Re: Reg DD Disclosing Fees Steve Doty
~MunQue~ Offline
Platinum Poster
~MunQue~
Joined: Jul 2006
Posts: 718
HERE! I'm here!
Thanks!!!
_________________________
The higher up the monkey climbs, the more you see of it's behind.


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