Curious if anyone has been cited by a Regulator for the fees disclosed on the TISA (ex: maintenance fee) versus the fee disclosed on the periodic statement? Our statements refer to a maintenance fee in the body (history) of the statement but at the top of the statement (discloses beginning balance+credits-debits-fees=ending balance) and the fee is referred to as a service fee.

We are being told we have a TISA violation.

Thanks in advance!

Unfortunately, yes. Many years ago - and if I remember correctly we also got dinged because it didn't match on the service charge brochure we were providing to customers, so you may want to check that as well. The Examiners really want to see consistency so the customer does not get confused.

I see this at nearly every new client we pick up. Reg DD is very clear that the wording must be consistent in all places. It's not a "big" violation, but it's a violation. As 80's Lady said, check everywhere you mention fees: website, brochures, TISA disclosures, periodic statements, etc.