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#1328912 - 01/22/10 04:36 PM Reg DD Overdraft Rules - DBA Account Clarification
Crazy Bank Lady Offline
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Crazy Bank Lady
Joined: Jun 2005
Posts: 109
Missouri
Could someone just confirm or clarify for me that since the rule for the overdraft fee disclosure grid on the periodic statements was written under Reg. DD it is a correct statement to say that I do not need to include this grid on DBA accounts as they are not for personal, family, or household purposes.

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Operations Compliance
#1329045 - 01/22/10 05:51 PM Re: Reg DD Overdraft Rules - DBA Account Clarification Crazy Bank Lady
Compliance4521 Offline
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Compliance4521
Joined: Jan 2007
Posts: 533
Washington
Reg. DD applies to "consumers", to include sole proprietors. Commercial DBA accounts are exempt under Reg. DD rules, therefore the overdraft fee disclosures is not applicable.

Lori

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#1329085 - 01/22/10 06:20 PM Re: Reg DD Overdraft Rules - DBA Account Clarification Crazy Bank Lady
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
"DBA" can apply to any type of business organtization ; i.e. corporation, partnership, LLC, etc. It is not a synonym for "sole proprietorship." Regardless, Reg DD does not cover business accounts, including sole proprietorships.

The boxes on the periodic statement showing aggregate returned and overdraft check fees are not required on any business purpose account.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1329284 - 01/22/10 07:46 PM Re: Reg DD Overdraft Rules - DBA Account Clarification Elwood P. Dowd
Compliance4521 Offline
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Compliance4521
Joined: Jan 2007
Posts: 533
Washington
Thank you for correcting the information I provided.

Lori

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#1333391 - 01/28/10 09:30 PM Re: Reg DD Overdraft Rules - DBA Account Clarification Compliance4521
sixspeed Offline
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Joined: Oct 2007
Posts: 16
Chicago Area

Our consumer statements have the total overdraft fees and total returned item fees as required, we do not currently have the boxes as does the model form, are the lines required.

thankyou

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#1333580 - 01/29/10 01:55 PM Re: Reg DD Overdraft Rules - DBA Account Clarification sixspeed
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Lines that combine into boxes are required. Emphasized in Fed Podcast.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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