We are offering a check deposit function with our mobile banking. Management wants to begin charging a fee of $.50 per check deposited beginning in June 2015. They want to list the fee on the schedule of fees and in the product FAQs on the website beginning now, and begin charging the fee in June. I am advising against this because I feel they need to advertise the product and its terms as they are now. If they want to implement a fee, then they can send a change in terms notice.

Now they are proposing listing the fee on the fee schedule and FAQ and stating that the fee is effective June 1, 2015.

What are your thoughts on this? Do we have a potential UDAAP problem?

stating that the fee is effective June 1, 2015.

I see absolutely no problem with this approach. I would not open such an account if I new this new fee was approaching. I think it is the opposite of any UDAAP. More information is always better than less.

I agree that more information is better, but I was concerned with it being so far in the future. Even if we state that we will begin to charge it as of a future date, will people remember that once they start getting the fee? Or would it be considered "unfair" to tell them 7 months in advance of a fee that they will be charged? Maybe I'm just being overly UDAAP-paranoid.

I agree with rlcarey... you're disclosing that the fee will be enforced beginning 6/1/15. You've met your requirement.

Do a quick analysis of how much it costs a teller to process a deposit. I've seen studies of true-cost of a basic transaction being in the $1-$2 range by the time processing, correction, proof, etc is all taken into account. Or, have the customer do that work, pay $0.30/item to your mobile capture provider, and your done. Charging a fee generates cost to your mobile RDC provider, but you save far more in efficiency gains.