Are the fees for holding a customer statement and for counter/temporary checks considered covered fees under Reg DD and thus subject to a 30 day notice if we are increasing the fee?

They are fees directly associated with the deposit account - so yes.

I would agree that the check fees are covered, but I wouldn't have thought the hold statement fee would be subject to notice since it is a type of ancillary service requested by the customer. They would be subject to customer agreement provisions for change.

It is no different from any other fee that may or mat not be charged. For instance, I have never had to place a stop payment on a check, but the fee is required to be disclosed. Holding statements is a similar circumstance. If it is a service that is offered, the fees must be disclosed and fall under Reg. DD.

The check fees, although need to be disclosed, do not require 30 days notice, see Reg DD:

Sec. 230.5 Subsequent disclosures:
(a) Change in terms
(2) No notice required. No notice under this section is required for:
(ii) Check printing fees. Changes in fees assessed for check printing.

Staff Interpretations:
(a) Change in terms
(a)(2) No notice required
(a)(2)(ii) Check printing fees
1. Increase in fees. A notice is not required for an increase in fees for printing checks (or deposit and withdrawal slips) even if the institution adds some amount to the price charged by the vendor.

Does the specific fee amount for checks need to be included on the disclosure, or can it state check printing fees may vary by style. Since the customer has options to choose from when selecting their checks for ordering? I was slightly confused because the Regulations states the following, but I wasn't sure if it applied to check printing fees?

3. Amount of fees. Institutions must state the amount and conditions under which a fee may be imposed. Naming and describing the fee (such as “$4.00 monthly service fee”) will typically satisfy these requirements.

I think the original question concerned counter check fees. I don't think it has anything to do with check printing fees, which is given some special treatment (favorable) under the regulation. I think that Analauditor's question has to do with a per use fee for counter checks, and that, I think, is a fee that would trip a CIT notice if increased.

Take a look at Model Form B-4. The amount of the checkprinting fee is not disclosed, but the fact that it varies depending on style, etc., of check selected is disclosed.

Maybe our "counter checks" are a different type of product than what is being referred to here... but...

Our "counter checks" are checks printed on demand for the specified account. We fee the customer $1 per check that we print for them.

In our case, this most certainly is a "check printing fee" (IMO)... Are you referring to a different type of product than described above?

I was referring to the check orders a customer places from a printing company through the bank(not counter checks).

Thanks
Kristy