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#1850976 - 09/11/13 03:54 PM Service Charges and Reg O
Anonymous
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Is there any reason, Reg O or otherwise, why we can't waive the service charges on accounts belonging to Directors, Prinicipal Shareholders, and Executive Officers? Not NSF fees, because I know we have to charge those according to Reg O, just things such as minimum balance fees, dormant fees, etc...

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#1851021 - 09/11/13 04:41 PM Re: Service Charges and Reg O Anonymous
rlcarey Offline
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rlcarey
Joined: Jul 2001
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Galveston, TX
No.
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#1851027 - 09/11/13 04:52 PM Re: Service Charges and Reg O Anonymous
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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The only federal rule on the topic relates to interest.

12 USC 376

376. Rate of interest paid to directors, etc.

No member bank shall pay to any director, officer, attorney, or employee a greater rate of interest on the deposits of such director, officer, attorney, or employee than that paid to other depositors on similar deposits with such member bank.


And by the way, December 23, 2013 is the 100th anniversary of the signing of the Federal Reserve Act.
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#1851040 - 09/11/13 05:24 PM Re: Service Charges and Reg O Anonymous
Anonymous
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Thanks for your help smile
Kathleen, if we waive a fee on an interest bearing checking account, do you think that could be construed as giving them a greater rate of interest?

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#1851047 - 09/11/13 05:34 PM Re: Service Charges and Reg O Anonymous
rlcarey Offline
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rlcarey
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Galveston, TX
Not that I have ever seen.
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#1851058 - 09/11/13 05:52 PM Re: Service Charges and Reg O Anonymous
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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If you are not a fed member bank, that will not apply to you.

I do know banks that do not allow the fee waivers to not have any issue but that is an internal decision.



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Kathleen O. Blanchard, CRCM "Kaybee"
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#1851090 - 09/11/13 06:38 PM Re: Service Charges and Reg O Anonymous
Elwood P. Dowd Offline
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Elwood P. Dowd
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Next to Harvey
Legal or otherwise, it still looks cheesy, particularly if its not done for employees.
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#1851193 - 09/11/13 08:08 PM Re: Service Charges and Reg O Anonymous
Anonymous
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We are a fed bank, so it would apply. Just not sure if, since service charges and interest are different things, it could ever be construed that greater interest was being given because of a service charge. Logic goes against it, but I have found that logic doesn't apply in some cases. smile

Ken,
Employees get it on one account, whichever one their paycheck is deposited to. So only slightly cheesey, lol.

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#1851211 - 09/11/13 08:25 PM Re: Service Charges and Reg O Anonymous
John Burnett Offline
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John Burnett
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Cape Cod
Waiving service charges -- other than OD fees, of course -- for employees and directors is pretty common, and I don't think you need to worry about service charges and interest being confused by examiners.
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#1851265 - 09/11/13 09:07 PM Re: Service Charges and Reg O Anonymous
Anonymous
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Thanks John!!

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