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#1975318 - 11/07/14 08:44 PM Mobile Deposits
Red Raiders Offline
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We are getting ready to offer mobile deposits for consumers. With this, we are assessing a charge of $.75 per deposited item. As this is a new fee do we need to send advance notice to our accountholders? We will be disclosing this to the customers who sign up for mobile deposits but didn't know if advance notice was required 30 days in advance for our entire customer base.
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#1975320 - 11/07/14 08:47 PM Re: Mobile Deposits Red Raiders
rlcarey Offline
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It is a fee associated with RDC. Why would anyone else need to know about it???
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#1975333 - 11/07/14 08:59 PM Re: Mobile Deposits Red Raiders
John Burnett Offline
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I'll sing harmony to Randy's response. Add it to your list of fees, if you wish, but there's no need to notify existing customers unless they wish to sign up for the service.
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#1975334 - 11/07/14 08:58 PM Re: Mobile Deposits Red Raiders
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That was my thought that only the affected customers would need to know and they would be notified when they signed up for the service. Just wanted to make sure I wasn't missing something.

Thanks for the response.
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#1977660 - 11/20/14 12:22 AM Re: Mobile Deposits Red Raiders
Jennifer Offline
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Joined: Jul 2009
Posts: 79
Pacific Northwest
I believe that you will need to provide an update to your EFT disclosure for the new service (and change the new account disclosure accordingly). This would not be to disclose the fee, rather the new EFT service. This could be accomplished via a statement message, marketing insert or other format to make it more of a new product announcement versus dry legalise. I would agree that this should be added to your Schedule of Fees.

Reg E - 205.7 (c) Addition of electronic fund transfer services. If an electronic fund transfer service is added to a consumer's account and is subject to terms and conditions different from those described in the initial disclosures, disclosures for the new service are required.

Reg E - 205.3 (b) Electronic fund transfer—(1) Definition. The term electronic fund transfer means any transfer of funds that is initiated through an electronic terminal, telephone, computer, or magnetic tape for the purpose of ordering, instructing, or authorizing a financial institution to debit or credit a consumer's account.
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#1992160 - 01/29/15 03:42 PM Re: Mobile Deposits Red Raiders
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I had another question that popped up on this:

When rolling this out we are going to offer the first six mobile deposits free each month, then $.75 for each one thereafter for the month. We have a free checking account a few hundred customers have (we no longer offer that product). Can we charge this "excess mobile deposit" fee on the free checking account?
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#1992182 - 01/29/15 04:12 PM Re: Mobile Deposits Red Raiders
rlcarey Offline
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Galveston, TX
It is a fee for an ancillary service that they have to sign up for, so yes.
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#1992203 - 01/29/15 04:54 PM Re: Mobile Deposits Red Raiders
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Phew! I was hoping this would be acceptable and that is the case. It is a separate service that they sign up for. Thanks for the response!
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