This is something I posted way back in 2006 on a similar question. And again this past June.
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Many, many years ago I worked for a bank that was audited by a State examiner specifically for dormant accounts. AT THAT TIME, we were told that unless a depositor was told of a specific dormant account fee, we could not charge such a fee. In other words, the customer had to be told at account opening. If it was added after the account was opened and say the account was already dormant and mail was returned, the customer would have never had knowledge of it. So it was invalid. If I recall, we had to refund over $10,000 in fees (a large amount in those days) to the State, as they were now the holder of the abandoned funds.
So what I'm basically saying is that make sure it's in your Fee Schedule, but you never know what an examiner will do......
UPDATE: Check the idfpr.com site. Maybe do a search for "dormant"?
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