I read that as of October 1, 2010, we will be required to use the term "Total overdraft Fees" on periodic statements. Does this mean that we have to change all the other places we list our "NSF Items Paid", to "Overdrafts Fees". This would include brochures and disclosures where we kept the name of the fees the same. It also says the we can continue to call the fees for items returned, "NSF items not paid". I would like to hear what other banks are doing. Are you just changing the box name of your NSF items paid to "Overdraft Fees" on your statement only or are you changing the name of the fee everywhere else you have it listed. Thanks.

No, that is not what it means. The only place in which the regulation requires that you use the phrase "Total Overdraft fees" is in the tabular totals required by section 230.11(a) of Regulation DD. Notice that the end of the revised Comment in Supplement I says, " This requirement applies notwithstanding comment 3(a)-2." That sentence makes the use of "Total Overdraft Fees" an exception to Comment 3(a)-2, which is where the mandate for consistent terminology is found.

John's obviously correct.

I'd make the descriptions consistent anyway. First, while the Fed may think the customer knows all those other fees are included in "total overdraft fees" at the bottom of the page, I don't think so. Second, some field examiners are not as well read as John.

As has been said:

What's in a name? that which we call an overdraft fee
By any other name would stink just as badly;

The ever quotable Ken comes up with yet another gem!

ROFL

Another question - if the customer does not incur overdraft fees is the grid of fees still required on the stmt?

I would say no, but you would have to have more sophisticated periodic statement writer software than I have seen. The statement writer software would have to know whether or not fees are being assessed this month or year to date.

Agreed. Regulation DD generally does not require irrelevant disclosures. You do not need to tell the DDA customer that her APYE for last month 0.00% or that her overdraft fees YTD are $0.00.