We are wanting to raise our dormant account fees from $5 to $10 per month (Oklahoma bank). We will change our new account disclosures of course, and I have suggested putting a blurb notifying customers of the change (thirty days)on DDA and Savings statements. However, most, if not all, of our dormant account holders have bad addresses and their statements are not mailed ("Hold at Bank"). We have made attempts to locate each customer, but what type of documentation will be needed for examiners for these customers we cannot locate? A returned statement or a returned "Have You Moved?" letter we send out after receiving mail back?

I would think either method would show your intention to notify the dormant accounts.

I would be visiting with your attorney to make sure you stay within State law. The States take a dim view of you taking any money that they feel belongs to them:

SUBCHAPTER 5. ALLOWABLE CHARGES AND DEDUCTIONS

735:80-5-1. Charges and deductions that may be withheld

(a) Charges shall not be deducted from unclaimed intangible property unless:

(1) A reasonable notice of service charges or deductions is given to the owner at the time the account is opened; or

(2) A schedule of service charges or deductions has been mailed to the owner; or

(3) A statement concerning such charges has been incorporated in the rules, regulations, or bylaws of the holder.

(b) Such charges or fees may not be excluded, withheld, or deducted from property subject to the Uniform Unclaimed Property Act if, under its policy or procedure, the holder would not have excluded, withheld or deducted such charges or fees in the event the property had been claimed by the owner prior to being reported or remitted to OST.

(c) If charges are deducted from property, a holder shall include or attach as a part of the report filed pursuant to the Uniform Unclaimed Property Act:

(1) The value or amount of each item or property before any charges are deducted there from;

(2) The amount of the charges deducted from each item and the date or dates on which such charges were deducted.

(3) Policy that the holder regularly imposes such charges and does not regularly reverse or otherwise cancel them.

(4) Such other information or documentation that substantiates the deduction of the charges.