Are financial institutions permitted to charge 'return deposit item fees' on Interest Bearing Real Estate Trust Accounts?
We are currently in the process of changing our fees. Some fees may increase and some fees may decrease. With that said do we still need to
send a notice to customers 45 days in advance of the changes?
My bank has a 30 day waiting and vetting period prior to us granting overdraft service. We do not have overdraft services that come with the account but rather it is our practice to offer an OPT-IN to Standard (payment of checks, ACH.) and then we offer another opt-in to Extended Service which allows the payment of ATM and one-time POS into overdraft under Regulation E. In this example, the customer opted in to both Standard and Extended Service. Customer received the Regulation E confirmation notice.
Without waiting the 30 days initially disclosed, my bank immediately paid into overdraft ATM and Debit card charges and fees but returned the checks that came through as insufficient. Once the 30 day vetting period for this customer had expired, they denied the customer for overdraft service but continued to allow only Extended service, ATM and One-time debit payments and
charges to go through. It is my understanding that the Extended Service under Regulation E is pursuant to the overdraft program offering and not to be used as a stand alone service outside the overdraft program. If we rejected the customer for our overdraft service, shouldn't that include all transactions?
We have an upcoming deposit account fee change requiring advance notice to affected account holders. If we know we have a bad address (statements have been returned), are we required to mail the notice to the last known address?
Can we charge a Money Market account a per item fee for each item that exceeds the allowable 6 withdrawals per month?
Can a savings account be charged an NSF fee?
Should a bank allow a customer to overdraw their account at the teller window by letting them withdraw any amount up to their OD limit and also charge them the normal OD Fees?
I am processing a Small Estate Affidavit that will require the bank to issue several cashier's checks to beneficiaries. Normally the bank charges a small fee to issue Cashier's Checks. Is there a problem charging a fee to issue cashier's checks from a deceased account holders account to pay the beneficiaries.
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.
Can the fee on overdrafts for paid checks vs return checks differ? Such as $25 fee for paid OD's and $30 fee for return.