Many years ago, possibly before the thought of federal preemption, the decision against BofA made it abundantly clear that service charges could continue on dormant account, but that any new charges, including increasing charges on existing accounts, was not allowed.
That was so long ago that BofA was only in CA.
Being relatively new to OCC regulation, could you please provide a cite stating that national banks can impose such a fee.
Al
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Al Miller, CRCM
Opinions expressed are my own and not necessarily shared by my employer.