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#2080484 - 05/25/16 11:24 PM Fee disclosure verbaige consitency
dg Offline
Platinum Poster
Joined: Jan 2005
Posts: 811
Pacific NW
Is it a requirement of Reg DD for the Fee description of an overdraft fee have to be the same (consistent on each form)on the TISA disclosure to the transaction fee description on the statement,to the statement table of totals, to the notice?

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Operations Compliance
#2080497 - 05/26/16 03:02 AM Re: Fee disclosure verbaige consitency dg
Inspector Offline
Gold Star
Joined: Apr 2016
Posts: 283
Dg - I have seen it required based on the commentary to TISA below,

1030.3—General Disclosure Requirements
2. Consistent terminology. Institutions must use consistent terminology to describe terms or features required to be disclosed. For example, if an institution describes a monthly fee (regardless of account activity) as a “monthly service fee” in account-opening disclosures, the periodic statement and change-in-term notices must use the same terminology so that consumers can readily identify the fee.
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Opinions expressed are my own and do not reflect legal advice or the opinions of my employer.

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