For the last 12 months we have been offering a "free checking" account that we are heavily advertising. The customer who opens the account receives a free gift. We are finding that many customers are opening the account, receiving the gift, and allowing the account to remain "inactive" with a small balance. Our operations group is proposing an $4 inactivity fee to kick in after 6 months of no activity on accounts with balances under $100 to help get these accounts off the books. Of course, we would have to change our disclosures and redisclose to existing customers if we do this. We currently disclose a "dormant" fee that kicks in after 2 years of no activity. I can't find any guidance whether or not a free account can have such an inactivity fee after a certain period. Are you aware of any other institutions charging such a fee? Can such a fee be structured in a way not to violate DD? Our marketing vendor assisting with this free checking account is also a proponent of this inactivity fee.
After an account has gone dormant, can it be put into active status with the customer's verbal request without having them do a transaction to the account?
What are the federal guidelines as they pertain to dormant accounts and which regulation do they fall under? I am looking specifically for length of time at which point an account is considered dormant. We are a federally chartered institution we should be following federal rules and not state rules.
Question: Our credit union is getting a substantial amount of returned mail from membership stating that the member is no longer at the last known mailing address.
I received a notice of levy from the state on one of our customers. The customer's account is dormant. Do I hold and remit the funds to the state, even though the status is dormant? Does it matter that the account is dormant?
Can a bank charge a dormant fee on offical bank checks (ex. money orders)? And would we have to pay the customer or state the full amount of the cashier's check?
Is there a law or regulation that requires signature cards attached to dormant accounts to be maintained under dual control and separate from all other signature cards?
If an IRA Account appears on a Dormant Accounts Report after being inactive for two years, can it be updated and removed from Dormant status even though you can't get in touch with the owners?
On dormant accounts if the bank already charges dormant accounts fee, is it okay to charge minimum balance, and hold mail fees. If so, what is the purpose of the dormant account fee? Furthermore is there any regulation I could look into for guidelines?
Is it permissible to charge our normal monthly service charge, in addition to a dormant account fee, on a dormant account?