Skip to content
BOL Conferences
Thread Options Tools
#2234350 - 04/07/20 04:00 PM waiving fees
Compliance Action Subscriber 1226 Offline
100 Club
Joined: Sep 2015
Posts: 198
We are considering waiving NSF and ATM, early W/D fees for customers that request this because of the coronavirus hardship - would this be considered a UDAAP - how would we document doing this or should there be a policy written for doing this

Return to Top
General Discussion
#2234352 - 04/07/20 04:02 PM Re: waiving fees Compliance Action Subscriber 1226
Skittles Offline
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
How would this be considered a UDAAP issue. Is it unfair, deceptive or abusive?

Do you plan on doing this across the board or just for those who ask? I know we have waived foreign ATM fees for all customers at this time.
_________________________
My Opinions Only

Return to Top
#2234358 - 04/07/20 04:57 PM Re: waiving fees Compliance Action Subscriber 1226
Compliance Action Subscriber 1226 Offline
100 Club
Joined: Sep 2015
Posts: 198
only for the ones that ask and because of hardship, was thinking it might be unfair if we don't do it across the board

Return to Top
#2234366 - 04/07/20 05:41 PM Re: waiving fees Compliance Action Subscriber 1226
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,685
Illinois
Since an overdraft is considered an extension of credit under Reg B, waiving for some and not for others based on our assessment of hardship = underwriting. Without policy/procedures to determine who gets the waiver and who doesn't you could have some serious fair lending questions to answer at the next exam.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top
#2234496 - 04/09/20 04:02 PM Re: waiving fees Compliance Action Subscriber 1226
burkemi Offline
Platinum Poster
Joined: Nov 2013
Posts: 549
Originally Posted by Compliance Action Subscriber 1226
only for the ones that ask and because of hardship, was thinking it might be unfair if we don't do it across the board


There are also many customers that will simply sit on these overdraft fees because they want to avoid confrontation, are embarrassed to ask, etc... even if he or she would really benefit.

The idea to help is a good one, but your safest bet would be to honor it across the board without requiring the customer to ask.
_________________________
I reject your reality and replace it with my own.

Return to Top
#2235041 - 04/16/20 08:19 PM Re: waiving fees Compliance Action Subscriber 1226
GoneToTexas Offline
100 Club
Joined: Jul 2007
Posts: 135
Texas
Why not waive the first "x" number of fees in a statement cycle for the next few cycles? The customer doesn't have to ask for it, so no embarrassment. Also, it shows we get it and we care.

Return to Top