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.
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?
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?
Were there any new developments affecting ACH operations?
What changes are coming for payments processing?
When will FinCEN raise the threshold for CTR reporting?
Have there been any significant BSA/AML penalties imposed on banks?
In light of the recent CFPB Consent Order against Regions Bank for charging Authorized-Positive OD fees, help me understand these were transactions that were not related to Reg E Opt In status? In other words, because these transactions had sufficient available balance it would not have mattered what there Reg E status was. Is that a true statement?
What’s the latest word on overdrafts and overdraft fees?
Our bank has limited the number of overdrafts an employee may have in a rolling 11 month period. Management now would like to treat employee like other bank depositors and eliminate the limit. Are there any compliance concerns with this action? My initial comment was that employees of a bank should be held to a higher standard as the general public is entrusting their funds in the integrity of the bank's staff. Thoughts?