Skip to content
BOL Conferences
Thread Options
#1975318 - 11/07/14 08:44 PM Mobile Deposits
Red Raiders Offline
Diamond Poster
Red Raiders
Joined: May 2013
Posts: 1,069
Compliance Land
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.
_________________________
How long until retirement?? smile

Return to Top
Deposits and Payments
#1975320 - 11/07/14 08:47 PM Re: Mobile Deposits Red Raiders
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
It is a fee associated with RDC. Why would anyone else need to know about it???
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1975333 - 11/07/14 08:59 PM Re: Mobile Deposits Red Raiders
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
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.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1975334 - 11/07/14 08:58 PM Re: Mobile Deposits Red Raiders
Red Raiders Offline
Diamond Poster
Red Raiders
Joined: May 2013
Posts: 1,069
Compliance Land
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.
_________________________
How long until retirement?? smile

Return to Top
#1977660 - 11/20/14 12:22 AM Re: Mobile Deposits Red Raiders
Jennifer Offline
Member
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.
_________________________
The opinions expressed are mine and do not necessarily reflect those of my employer.

Return to Top
#1992160 - 01/29/15 03:42 PM Re: Mobile Deposits Red Raiders
Red Raiders Offline
Diamond Poster
Red Raiders
Joined: May 2013
Posts: 1,069
Compliance Land
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?
_________________________
How long until retirement?? smile

Return to Top
#1992182 - 01/29/15 04:12 PM Re: Mobile Deposits Red Raiders
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
It is a fee for an ancillary service that they have to sign up for, so yes.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1992203 - 01/29/15 04:54 PM Re: Mobile Deposits Red Raiders
Red Raiders Offline
Diamond Poster
Red Raiders
Joined: May 2013
Posts: 1,069
Compliance Land
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!
_________________________
How long until retirement?? smile

Return to Top

Moderator:  John Burnett