We are using Jack Henry's new ODP statement (OD6288). We are a 20/20 bank. Our internal auditor noted that the Interest Charge is appearing in the Transactions section AND in the Interest Charged section.

Commentary section 226.7(b)(2) states that creditors must group all fees and all interest separately from transactions and may not disclose any fees or interest charges with transactions.

I noticed that the statement also includes a balance column that reflects the new balance after each transaction. I'm thinking that Jack Henry is including the Interest Charge in the Transaction section so that the customer can see how the New Balance was arrived at.

The commentary is pretty clear. So it appears that we might have a problem. We've opened a case with them but I was wondering if anyone has any information concerning this.

I just looked and that's how our statements are printing as well. I'd be interested to know what you find out from JH.

There was a "Critical Issue Fast Fax" issued by Jack Henry on August 4th regarding the LN6289 statements. There were two issues identified regarding the "Fees Charged" information. The fix depends on whether you are on Release version 2009 or 2010.

Perhaps your Jack Henry expert can locate this document and deternmine the action needed.

Yes, I saw that. However, the statement we are dealing with is OD6288, not LN6289. I our case, the interest charge is not capitalized.

226.7(b)(2)-1 Commentary states (emphasis added):

1. Multifeatured plans. Creditors may, but are not required to, arrange transactions by feature (such as disclosing purchase transactions separately from cash advance transactions). Pursuant to § 226.7(b)(6), however, creditors must group all fees and all interest separately from transactions and may not disclose any fees or interest charges with transactions.

226.7-1 Commentary says: 1. Multifeatured plans. Some plans involve a number of different features, such as purchases, cash advances, or overdraft checking. Groups of transactions subject to different finance charge terms because of the dates on which the transactions took place are treated like different features for purposes of disclosures on the periodic statements. The commentary includes additional guidance for multifeatured plans.

So, I'm just trying to figure out - are overdraft lines of credit considered multi-featured plans in that definition, especially if all transactions in those plans are subject to the same interest rate unlike credit cards which often apply different interest rates to different types of transactions? (what is meant by "overdraft checking"?). What about consumer lines of credit accessible only via advance in the bank?

Perhaps JH's position that it's okay for the interest charges to be in the transactions section is because they don't consider these products to be multi-featured plans subject tot that provision on the commentary?