Others will give you a more exacting answer, but IMHO, the bank should not get undue enrichment from their mistake, If the calculations are on a monthly basis then the bank is violating their contract with the customer, and could additionally be charged with UDAAP. There may be de minimus caveats in the regulation that I'm unaware of, but the charges are not what was agreed to in the contract.
Last edited by Rocky P; 04/25/19 06:44 PM. Reason: added comment
Integrity. With it, nothing else matters. Without it, nothing else matters.