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#1473238 - 11/29/10 05:52 PM Open End Statements - Fees
Lake Offline
New Poster
Joined: Nov 2010
Posts: 1
Reg Z, Periodic Statement rules affecting open-end (not home secured) credit require that any fees be grouped together under the heading 'Fees' and be 'itemized'. Currently our processor is only able to 'itemize' by fee 'type', i.e. Annual Fee, Late Fee, Automatic Transfer Fee and Bank Assisted Transfer Fee. If there is more that one transfer fee in a 'type', the statement just shows the total for the period. Thoughts on whether or not this meets the Reg Z requirements?

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#1474177 - 12/01/10 02:39 PM Re: Open End Statements - Fees Lake
Phoenix Offline
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Phoenix
Joined: May 2003
Posts: 832
southeast
There's no way to show the transfer fee as a transaction?
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#1474430 - 12/01/10 05:41 PM Re: Open End Statements - Fees Lake
Tom Easterday Offline
100 Club
Joined: Oct 2000
Posts: 140
Orange County, CA
My understanding is that the fees must be individually itemized in the fees "box." If you charge 3 "tranfer fees" during the period, each must be listed. Then, after all individual fees are itemized, the total for the period is shown.

Just having a total of transfer fees for the period (assuming more than 1 was assessed) is incorrect.
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