I have recently started an audit of service charges (My first audit on this topic since I was hired). The CU where I work aggregates all atm fees for the month and on the last day of the statement cycle puts in a line item for the entire amount. I have always been under the impression that fees need to be identified as to what the fees were for and they also have to have consistent wording with the fee statement. We are putting into one fee the fees charged for all balance inquiries and the fee charged for all foreign ATM usage.

I don't believe that this is acceptable because of information in the REG DD commentary about consistent wording but the company that has done the compliance audits and the state examiners have never said a word about this so I am very confused.

Thanks for any help.

You are absolutely correct as per the commentary:

2. Itemizing fees by type . In itemizing fees imposed more than once in the period, institutions may group fees if they are the same type. (See §230.11(a)(1) of this part regarding certain fees that are required to be grouped when an institution promotes the payment of overdrafts.) When fees of the same type are grouped together, the description must make clear that the dollar figure represents more than a single fee, for example, “total fees for checks written this period.” Examples of fees that may not be grouped together are—

i. Monthly maintenance and excess-activity fees

ii. “transfer” fees, if different dollar amounts are imposed” such as $.50 for deposits and $1.00 for withdrawals

iii. fees for electronic fund transfers and fees for other services, such as balance-inquiry or maintenance fees

The question regarding previous compliance auditors and examiners is really moot. Either they did not specifically look at this issue or they missed it. Not ever specifically catching an issue before does not mean that the practice has received their blessing.

Thanks for your help. Sometimes you feel like you have lost all your intelligence dealing with some of these people. You are helping me keep my sanity.