Thread Options
#1975200 - 11/07/14 05:50 PM Advertising a future fee
TeeBee Offline
Member
Joined: Jun 2007
Posts: 67
New York
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?

Return to Top
Marketing
#1975226 - 11/07/14 06:22 PM Re: Advertising a future fee TeeBee
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 76,149
Galveston, TX
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.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1975231 - 11/07/14 06:33 PM Re: Advertising a future fee TeeBee
TeeBee Offline
Member
Joined: Jun 2007
Posts: 67
New York
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.

Return to Top
#1975256 - 11/07/14 07:08 PM Re: Advertising a future fee TeeBee
Milby Offline
Platinum Poster
Joined: Apr 2007
Posts: 953
Tejas
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.

Return to Top

Moderator:  Andy_Z, MoneyMaker