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#323169 - 02/28/05 03:03 PM Increase of Monthly Maintenance Fee
M&M Offline
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Joined: Nov 2003
Posts: 527
Midwest
We are looking to increase our monthly maintenance fee by $1.00 for all checking account types. This fee currently differs depending on account type. Our retail group wants to put one message on statements indicating that the monthly fee will increase by $1.00,however in reading the Reg DD commentary, it appears we should list the new fee. This would require a different statement message for each account type. Any thoughts would be appreciated.

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#323170 - 02/28/05 03:38 PM Re: Increase of Monthly Maintenance Fee
Andy_Z Online
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Andy_Z
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Posts: 27,353
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I do believe the intent is to list the dollar amount. While some may argue that the consumer could do the math and the fee is above, in the statement, that isn't what is required and you could be criticized. The model clause in B2 is indicative that the fee itself should be listed.

I would let your programming folks make a statement entry for each category rather than worry about this. The Chicago FDIC did list Reg. DD subsequent disclosures as a common violation.
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AndyZ CRCM
My opinions are not necessarily my employers.
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#323171 - 03/01/05 12:38 PM Re: Increase of Monthly Maintenance Fee
M&M Offline
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Joined: Nov 2003
Posts: 527
Midwest
Thanks Andy! I agree- I'd rather be safe than sorry...

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