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#450070 - 10/31/05 05:38 PM SUSTAINED OVERDRAFT FEE - ANYONE DOING THIS?
Kay Offline
100 Club
Joined: Mar 2004
Posts: 248
Midwest
We are seriously comtemplatiing charging a "sustained overdraft fee" after 7 days of the account (commercial and retail) being overdrawn. Are there any particular compliance issues that we should be considering other than the 30 day notification to existing customers and revision of our TISA terms and conditions?

Any comments will be appreciated.

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General Discussion
#450071 - 11/01/05 01:03 AM Re: SUSTAINED OVERDRAFT FEE - ANYONE DOING THIS?
flaire Offline
100 Club
flaire
Joined: Sep 2005
Posts: 228
sw us
Many banks charge a daily OD fee - some based on the dollar amount of the OD - in addition to an NSF charge. There is no prohibition against it as long as it is properly disclosed on your Fee Schedule and in your Account Agreement.

That being said, I would caution you to read the revisions to Reg. DD regaridng OD Protection programs before you venture into anything new. With all the hype about OD fees right now, it would be prudent to show that you have conducted due dillegence in this area to any examiner that walks in the door.
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#450072 - 11/01/05 03:35 PM Re: SUSTAINED OVERDRAFT FEE - ANYONE DOING THIS?
LoisLane Offline
Diamond Poster
LoisLane
Joined: Oct 2001
Posts: 1,570
Wisteria Lane..
Regarding a daily overdraft fee, I understand that this isn't allowed in some states because of their state laws.
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