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#1483558 - 12/21/10 06:54 PM YTD Overdrafts Amount
PBate Offline
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Joined: Jun 2007
Posts: 42
If a bank does not have an ODP program, and subsequently does not charge Overdraft fees, must there still be a box on the statement listing total statement period and YTS overdraft charges?

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Deposits and Payments
#1483613 - 12/21/10 07:39 PM Re: YTD Overdrafts Amount PBate
Georgia Plum
Unregistered

You don't charge for any NSFs or returns, ever? If you don't, then there's nothing to report on the statement. However, the reporting requirement is not tied to an ODP program. If you charge ANY fees for NSF or return, then it must be reported on the statement.

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#1483617 - 12/21/10 07:41 PM Re: YTD Overdrafts Amount PBate
John Burnett Offline
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John Burnett
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Surely this hypothetical bank has customers that write checks that would overdraw their accounts. Surely the hypothetical bank would either pay such a check and charge an overdraft fee or refuse to pay such a check and charge a fee for returning the check unpaid. In either case, the fee charged would have to be reported in the "grid" required by Regulation DD, section 230.11(a).
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#1483672 - 12/21/10 08:27 PM Re: YTD Overdrafts Amount John Burnett
banker-12 Offline
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Joined: May 2007
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Do we have to disclose "Previous YTD" fee totals on our January statements?

thanks,

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#1483684 - 12/21/10 08:35 PM Re: YTD Overdrafts Amount banker-12
John Burnett Offline
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The answer is in comment 5 to ยง230.11(a)(1):
Quote:
5. 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.


If your January statements cover 1/1/11 through 1/31/11, your YTD totals should only include amounts charged in 2011.
Last edited by John Burnett; 12/21/10 08:37 PM.
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#1483811 - 12/22/10 12:04 AM Re: YTD Overdrafts Amount John Burnett
banker-12 Offline
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Joined: May 2007
Posts: 1,243
Our statement period begins on the 10th of each month, the January 2011 statement is from Dec 10 - Jan 9, but the YTD totals is only for 2011 (Jan 1 - Jan 9). Our core system adds additional totals (previous ytd) on our January statement. Is it okay to add the previous ytd totals for both ovedraft fees and return item fees in addition to "total for period" and "total ytd"?

thanks,

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#1483835 - 12/22/10 12:58 PM Re: YTD Overdrafts Amount banker-12
John Burnett Offline
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While the urge to provide more information than required may feel right, you have to stick to the regulation. You can only include the four amounts called for (you can omit any with a $0.00 value). In your case, Comment 5 quoted above is specific to your situation. For your YTD totals, you can include fees from the period 1/10/10 through 1/9/11 or from the period 1/1/2010 through 12/31/10. The statement period that begins in December has to include totals for a twelve month span.

When you print statements for the period beginning in January and ending in February 2011, your YTD totals will start with fees from 1/1/11 or from 1/10/11.
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