Our processor tells us that they can't change the wording in the "Summary of Overdraft and Returned Item Fees" box on the bank statements.. that they used the descriptions that matchs the recommended wording of the regulation. Our disclosures state "Insufficient (NSF) Item Paid" and "Returned Insufficient (NSF) Item". The bank does not charge an Overdraft Fee.
The NSF Items Paid fees are totaling in the Total Overdraft Fee Box. What do you recommend?

An Insufficient Item Paid Fee and an overdraft fee are one and the same...If you pay an item against insufficient funds, you have created an overdraft. The regulation requires the term Total Overdraft Fees.

But I thought I have seen other banks charge an NSF fee and then an Overdraft Fee also.......... ??

First, let's address the consistent disclosure requirement. There is an exception to that requirement when it comes to the term "Total Overdraft Fees," which must be used in the statement grid modeled after Model Form B-10 in Regulation D. The exception is provided in Comment 11(a)(1)-2.

For the purpose of this total, the term "overdraft fees" includes a fee for paying any item against insufficient funds, whether based on the ledger balance, the fact that funds are subject to a hold or because previously deposited funds are not collected. It also includes any fee imposed because the account is in overdraft status, such as a continuing OD fee or daily overdraft fee.

So regardless of what you may call it, you charge an overdraft fee for the purpose of the 1030.11(a) disclosure, and you have to include it in the required table, which must include the words "Total Overdraft Fees."

We had the same issue at our bank.

Regulators said it was okay to have the "overdraft fee" named something else within the statement, as long as that corresponded to the fee schedule, however, the overdraft box must use the prescribed overdraft terminology. As long as the box functioned appropriately this was okay.

However, all regulators are different and their interpratations/opinions are ever-changing.

The rule is in Reg DD, and the only agency with "license" to interpret it is the CFPB.