Are we required to disclose the daily overdraft caps and deminimis amount on the Truth-in-Savings disclosure? I know that we must disclose the daily overdraft cap on the Model Notice A-9 under Reg E. Also, are we required to provide a change in terms notice to existing customers under either Reg DD or Reg E?

Also on the fee descriptions used for overdrafts, is it ok to use "Paid item fees" or should we state them as "Overdraft fees"? If we change the fee description from "Paid Item Fees" to "Overdraft Fees" should we provide notice to customers?

On the A-9 Model Notice under "What fees will I be charged if [institution name] pays my overdraft?

Do we have to specifically state what the limit is on the total fees or do we state that there is "a limit" on the total fees we can charge you for overdrawing your account?

I recommend using the term "overdraft fees" because that's how you have to label them in the periodic and YTD totals on statements (even though you could use "overdraft fees" there and something different everywhere else.

Truth in savings and Reg DD don't require the disclosure of daily fee caps. I think you could make a case to say it requires disclosing a de minimis overdraft for OD fees, though.

With the possible exception of the de minimis OD amount, neither Reg DD nor Reg E requires a change in terms notice for the changes you're describing.