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#2269516 - 04/22/22 02:13 PM Periodic Statement Content and Fees
TeamComply Offline
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If the monthly balance falls below $x.xx in the month, a $3.00 maintenance fee is charged on savings accounts. For savings account statements that are generated quarterly instead of monthly (due to no EFT activity), this fee could be charged 3 times (once for each month in the quarter). Each fee is itemized on the statement. Are we also required to provide a total of fees assessed on the statement (in summary form), such as "total maintenance fees" or is the separate itemization within the periodic statement sufficient? Thanks.

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#2269520 - 04/22/22 02:29 PM Re: Periodic Statement Content and Fees TeamComply
rlcarey Online
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rlcarey
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Galveston, TX
(3) Fees imposed. Fees required to be disclosed under § 1030.4(b)(4) of this part that were debited to the account during the statement period. The fees shall be itemized by type and dollar amounts. Except as provided in § 1030.11(a)(1) of this part, when fees of the same type are imposed more than once in a statement period, a depository institution may itemize each fee separately or group the fees together and disclose a total dollar amount for all fees of that type.
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#2269521 - 04/22/22 02:38 PM Re: Periodic Statement Content and Fees rlcarey
TeamComply Offline
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Thanks, so it sounds as though we have the option?

However, based on the official interpretation to that same section 1030.6(a)(3) item 2 states: "Examples of fees that may not be grouped together are - i. Monthly maintenance and excess-activity fees." So then maintenance fees should be itemized separately, rather than summarized/grouped together?

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#2269522 - 04/22/22 02:46 PM Re: Periodic Statement Content and Fees TeamComply
rlcarey Online
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rlcarey
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Galveston, TX
If you have multiple monthly maintenance fees you can lump them together. You cannot lump them together with excess transaction fees. If you disclosed a "monthly maintenance fee" of $3 in your TISA disclosure, IMHO - I think you would be a fool to not itemize them and disclose it as $9 on a quarterly statement in this picky CFPB environment.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2269527 - 04/22/22 02:56 PM Re: Periodic Statement Content and Fees TeamComply
TeamComply Offline
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So we do itemize each fee separately on the statement, for example:

$3.00 maintenance fee 1/31/22,
$3.00 maintenance fee 2/28/22 and
$3.00 maintenance fee 3/31/22,

Our problem is that the "total service charge today" field available from our core system, only looks at the fee assessed on the day the statement cycles, so it is programmed to only list $3.00 here (instead of $9.00) because there was only a $3.00 fee assessed on the day the statement cycled. This has only been a problem on quarterly statements. So that was the reasoning for my question, on whether both are technically required....itemized separately and grouped together providing a total of fees. Our core programming set-up seems misleading and confusing, so if we aren't required to provide the total fees assessed, I think we should eliminate and continue itemizing them separately.

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#2269529 - 04/22/22 03:10 PM Re: Periodic Statement Content and Fees TeamComply
rlcarey Online
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rlcarey
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Posts: 79,643
Galveston, TX
Only OD and NSF are required to be disclosed in the table. Total maintenance fees is not required to be disclosed.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2269532 - 04/22/22 03:18 PM Re: Periodic Statement Content and Fees rlcarey
TeamComply Offline
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Just to clarify, this summarization of "total maintenance fees" is located outside the OD fee totals box/table required under 1030.11(a), it is just an account activity summary section near to the top of the periodic statement that includes other summary type information such as number of days in statement period, average balance, YTD interest, etc.

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