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#1395605 - 05/25/10 03:58 PM Reg DD disclosure of Overdraft Fees
Confused Again Offline
Junior Member
Joined: Apr 2010
Posts: 26
I recently went to work for a new bank and I notice that the fee disclosure for overdrafts simply indicates "Overdraft Charge" and the amount of the fee - if does does describe the fee or indicate that it will be assessed for each day the account is overdrawn.

I believe that Sec 230.4(b)(4) requires a more detailed disclosure - an expalnation of how the fee will be determined and under what conditions it will be assessed.

Am I expecting too much or is this disclosure inadequate.

Thanks.

bb

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Operations Compliance
#1395615 - 05/25/10 04:10 PM Re: Reg DD disclosure of Overdraft Fees Confused Again
Doug Hendrickson Offline
Power Poster
Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
Our fee disclosure just had "fee for each insufficient funds debit returned unpaid" and "fee for each debit paid that creates an overdraft" and the amount.

After an examination we added the words "This fee applies to insufficient funds (or overdrafts) created by check, in-person withdrawal, ATM withdrawal, or other electronic means".

Our other fee is listed as "Daily Overdraft Fee (not applicable to savings accounts) and the amount.

I'm also trying to gain agreement to make these even more clear to our customers, similar to the Reg E disclosure, even though, due to our overdraft service we don't need to send that disclosure since there is nothing to opt out of.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1395626 - 05/25/10 04:19 PM Re: Reg DD disclosure of Overdraft Fees Confused Again
Confused Again Offline
Junior Member
Joined: Apr 2010
Posts: 26
Thank you Doug. I think the word "daily" makes it clear that it could be charged more than once. Ours on the other hand does not, and I feel uncomfortable about that.

bb

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#1395654 - 05/25/10 04:34 PM Re: Reg DD disclosure of Overdraft Fees Confused Again
Confused Again Offline
Junior Member
Joined: Apr 2010
Posts: 26
I now notice a more disturbing part of this disclosure - it indicates the fee will be "Prime Rate plus 5.5% minimu of $5.00" - Are we now getting into Reg Z issues?

Thanks.

bb

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