For statements that end in January where the period includes two calendar years (e.g. 15 days in Dec 2009 and 15 days in Jan 2010, how do you show the "calendar year" YTD amount in the disclosure table? Do you show two items YTD 2009 with amount and YTD 2010 with amount? I didn't see any reference to this in the final rule (but maybe I missed it).

From the current commentary:

7. Totals for the calendar year to date. Some institutions' statement periods do not coincide with the calendar month. In such cases, the institution may disclose a calendar year-to-date total by aggregating fees for 12 monthly cycles, starting with the period that begins during January and finishing with the period that begins during December. For example, if statement periods begin on the 10th day of each month, the statement covering December 10, 2006 through January 9, 2007 may disclose the year-to-date total for fees imposed from January 10, 2006 through January 9, 2007. Alternatively, the institution could provide a statement for the cycle ending January 9, 2007 showing the year-to-date total for fees imposed January 1, 2006 through December 31, 2006.

Thanks Ken...at least the info was not in to final rule that I reviewed. I should have thought to look at the current commentary.

I covered the Reg DD rules changes in detail, along with a discussion of the ODP Guidance Best Practices and the proposed Regulation E amendments Tuesday in a webinar.

CD-ROM copies of the webinar, including the materials, slides, and the Q&A document covering some challenging questions, can be ordered in the Banker Store. Click here for more information.

I attended the webinar on Tuesday. Have a couple of questions now that I am rereading the materials. Are there any size requirements for the Sample Form B-10 from Appendix B? Size of the table or the size of the fonts used in the tabular format? I know the format must be "substantially similar" but any further suggestions would be appreciated.

Size Requirements: No. The general clear and conspicuous requirement of the regulation would apply, so I recommend the text in the table be no smaller than the text on your statement generally.

Thank you!

I was reviewing the upcoming Reg. DD changes and came upon the following statement in the commentary: 230.11(a)(1)2. relating to fees required for the statements:

"...It does not include fees for transferring funds from another account of the consumer to avoid an overdraft, or fees charged under a service subject to Reg. Z".

This threw me for a loop. Does that mean the only fee that requires YTD totals are the discretionary overdrafts and actual returned checks?

Lori

Yes, but it also includes daily or continuous OD fees, if you access them.

What this is saying is transfer fees or Loan fees (if a DDL) do not have to be included in the MTD and YTD totals.