A little while back, the bank made the decision to increase the minimum amount before an NSF fee was charged from $2.00 to $5.00. While this change was made on the main parameters, it was not changed on the bounce parameters. So, any account that had bounce protection and was overdrawn between $2.01 and $5.00 was charged an NSF fee and should not have been. My question is this, since we don't advertise the minimum amount and it's not in our disclosures anywhere, are we required to refund these fees? Of course we have had no complaints from customers since they were unaware that they would not be charged for an overdrafts less than $5.00. I know the right thing to do is to research and refund those fees, but are we required to?
Thank you!

Does your bank only do the right thing when people are looking? That is the first question I would ask, your answer comes from there.

If a regulator were to come looking, would they think maybe you didn't make this change in order to increase fee income?

Thanks for your reply. No, we don't do the right thing only when people are looking. My main problem/question was that no where is it documented that we were changing this and it's almost like upper management made the decision & it just didn't get done. It wasn't communicated to anyone, including other employees. I guess, I should've worded my first post a little differently. And, I did go ahead and do some research and we refunded the 1 fee I found.

well, management should make sure if they are changing fees that it is disclosed not just to customers but employees as well. No disclosure means no fee change. I can just imagine senior managers meeting:

M1 - well, we changed this fee and our expected to make more fee income, but our numbers are flat

M2 - yeah, makes no sense. did you update the fee tables?

M1 - Me? I thought you were updating it

M2 - Not me, maybe M3

M3 - nope, not me. Huh, maybe that is why our numbers haven't changed...