Skip to content
BOL Conferences
Learn More - Click Here!

Thread Options
#1634811 - 12/02/11 05:53 PM Limit of Daily Overdraft Fees
fmb Offline
Member
Joined: Sep 2003
Posts: 97
We know it is required to disclose the daily overdraft fee limit on the Opt In / Opt Out disclosure. HOWEVER, is it required to be disclosed in the Reg DD disclosure?

Return to Top
Operations Compliance
#1634869 - 12/02/11 06:59 PM Re: Limit of Daily Overdraft Fees fmb
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
No, it is not specifically required. Some banks, in fact, have specifically avoided doing it because they felt their customers might try to "work the system" to get free overdrafts. My take? Those same banks are under no obligation to pay the N+1 overdrawn check if the daily fee limit is for N checks only. Instead, they can bounce the N+1, N+2, etc., checks and impose a returned check unpaid fee -- and maybe even provide a lesson to the depositor.

So, in spite of the fact that Reg DD doesn't require the disclosure of a daily cap, I recommend making the disclosure in the interest of clarity and that "buzzword du jour" -- transparency.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top

Moderator:  Andy_Z, John Burnett