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#2189275 - 08/15/18 07:31 PM Free Checking Accounts
Bbgreen Offline
Member
Joined: Jan 2014
Posts: 76
Texas
Does anyone offer a free checking account that requires certain standards to be met?
For instance, you have to have so many debit card transactions per month and etc?

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General Discussion
#2189277 - 08/15/18 07:36 PM Re: Free Checking Accounts Bbgreen
osucpa Offline
Diamond Poster
Joined: May 2011
Posts: 1,406
Anything called "Free" is a hot topic for examiners and auditors. It is difficult to call an account free if you must do something.

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#2189283 - 08/15/18 08:05 PM Re: Free Checking Accounts Bbgreen
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
§1030.8(a)(2)
An advertisement shall not:
(2) Refer to or describe an account as “free” or “no cost” (or contain a similar term) if any maintenance or activity fee may be imposed on the account. The word “profit” shall not be used in referring to interest paid on an account.

If the depositor fails in his monthly checklist to have a free month, there will be a maintenance or activity fee. Since such a fee "may be imposed on the account," you can't call it a free account.

You can say that you will waive the fees if the depositor. . . . . But you'd better be careful and transparent about how the program works, and definitely not make it incumbent upon the depositor to notify the bank that he's met the criteria.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2189350 - 08/16/18 02:28 PM Re: Free Checking Accounts Bbgreen
Christy Goza Offline
100 Club
Joined: Jun 2010
Posts: 118
Cleveland, TN
Our Free Checking is now called eChecking. Same account, same features, no monthly service charge, but we DO NOT use the word "Free".
_________________________
Christy Griffith

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