A rule of thumb is to restore the customer to the position he or she would be in but for the unauthorized EFT. If the customer lost interest in the deposit account, restore it. If the customer incurred bank fees (minimum balance, overdraft, OD transfer) that would not have been imposed but for the unauthorized EFT, refund them. If the customer incurred interest charges in an overdraft line of credit based on a transfer that would not have been made but for the unauthorized EFT, refund it.
If the customer lost interest in a savings account because funds were transferred from that account to cover an overdraft caused by the unauthorized EFT, restore that interest.
Some banks have gone so far as to reimburse their customer for fees imposed by third parties -- a bad check fee incurred when the customer's check bounced to the grocery store, if the fee would not have been imposed had the unauthorized EFT not occurred. Reimbursement of third-party fees is not required by the regulation, however.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8