09/08/2024
We have an individual account that has been receiving recurring ACH debits monthly. The account owner died 6 years ago. The bank just found out about the death only days ago. No personal representatives have come forward or are known to contact. The most recent ACH debit was paid and overdrew the account. The account has now been overdrawn for 45 days.
Can we return the ACH debits that occurred after the date of death? Although the debits have been occurring for years, the bank just became aware of the death of the account owner.
07/28/2024
If we elect to update our disclosures on the circumstances that may trigger overdraft charges, do we have to disclose the order in which we post debit and credit items to deposit accounts?
07/28/2024
When is the CFPB likely to issue a final regulation making banks over
$10 billion in assets cut their overdraft fees back to a breakeven amount or start
treating overdrafts as extensions of open-end credit subject to Regulation Z?
07/21/2024
Our institution has chosen not to charge NSF fees on ANY ATM/debit
card transactions whether they are one time or recurring. Having said that, if we
are in an APSN situation at end of day and the account is now overdrawn, we
DO charge an Overdraft Fee (even if the only item causing the overdrawn
balance is the ATM/Debit card transaction). Would this be perceived at
UDAP/UDAAP? Additionally, both NSF fees and OD fees are the same amount.
04/23/2023
When reading the Consumer Financial Protection Circular 2022-06, we are trying to understand if banks are not allowed to charge an overdraft fee on a transaction that was authorized positive and settled negative, regardless if they had OD privilege or not? In the Circular 2022-06, it states that overdraft fees can be deemed unfair acts or practices even when the financial institution complies with federal regulations including Regs Z and E.
04/09/2023
When reporting an overdrafted account to Chex Systems , if it is a sole owner is an LLC business account do we report it with the TIN or the owners Social Security Number?
02/12/2023
We have changed our verbiage on our fee schedule to match the verbiage on our important terms and conditions regarding representments of checks. I was going to send out a letter with the updated fee schedule, but due to cost I would like to include the separate letter in the statement envelope. Does anyone see an issue with this?
01/01/2023
Were there any new developments affecting ACH operations?
12/25/2022
What changes are coming for payments processing?
12/18/2022
When will FinCEN raise the threshold for CTR reporting?