Our institution is based in Missouri, but we offer an online savings account. We are wondering about what state laws we use for charging dormant/inactive fees to accounts? Missouri Law is that once an account is inactive/dormant for twelve months we can charge a fee up to $5.00 a month. Then after five years of inactivity, the account is considered abandoned and will need to be sent to the State Unclaimed Property department. If a customer from different states opens accounts online with us, do we abide by Missouri Law or the state law which they reside in?
If an IRA is dormant for 5 years and the customer is 50 years old, do I need to send it to unclaimed property?
Are dormant accounts not subject to receive a monthly statement, or is it still required to be sent via Reg DD?
How much time does it really take for an account to be dormant?
Is there a regulation that states when an HSA account goes dormant? Am curious as to how long an account can stay active with no activity before it is considered to be dormant. Is this something that the bank has to figure out and disclose or is there a required time frame that we must follow.
Our Retail Division is getting very creative in coming up with fees that we have not charged in the past. I understand that dormant/inactivity fees are defined at the State level and are allowed on accounts advertised as "free." Would the same hold true for debit card inactivity and/or online banking inactivity fees? Would these fees be allowed on "free" accounts if properly disclosed? I have the same question for return mail fees.
Is it mandatory for a bank to send notices when an account status changes from active to dormant? We send notices when the account status changes from dormant to active but not the other way.
What is the procedure to activate dormant account with either or survivor instruction if any one comes in the branch to activate account with single identity?
I have two questions in regards to dormant accounts. We consider accounts to be dormant after 24 months of inactivity.
1.Are there varying state laws when it comes to the ability to charge a monthly fee on dormant accounts?
2.If we have a customer that has multiple accounts and they are like titled, same address, can we transfer the funds to an associated active bank account if we disclose this to our clients via some manner of electronic communication?
At my bank, we are trying to decide if inactive accounts and dormant accounts are the same. What are your ideas on this? We are trying to determine for yearly unclaimed funds reporting purposes.