Is there really any difference in assessing continuous overdraft fees based on business days versus calendar days and is there any regulatory guidance regarding assessment of such a fee on a calendar day when the bank is not open for business such as Saturday, Sunday or holidays which might tend to penalize the customer?
A large amount of our bank’s Net Income Before Taxes and Extraordinary Items, shown on our Call Report or in general ledgers, consists of fees associated with the automated ODP product. Is this of any concern to our regulatory agencies and do we need to be monitoring the impact of overdraft fees to our bottom line?
Much of the guidance regarding automated overdraft speaks to “alternative products”. What are these products and are we required to have them and how do we advertise them to our account holder base?
Does the assessment of an automated overdraft fee create issues for other consumer protection regulations and vice versa?
Do you have any guidance on what may be considered an appropriate automated overdraft fee whether it’s the initial fee or one for continuous overdraft?
For those banks with an automated overdraft protection program, such as bounce protection, does a switch from a ledger-balance method to an available-balance method for the purpose of determining an assessment of an overdraft fee create any consumer issues?
Is there a regulatory limit on the number of overdraft charges that can be applied in one business day?
Is signature needed for OD transfer service? Our "overdraft" product does not qualify as overdraft under 12 CFR 1005, as it's simply a transfer between the consumers accounts. The consumer receives two free transfers per year but is subsequently charged $0.50 for each transfer thereafter. Is the consumer's signature required to link his/her deposit accounts for this "overdraft" service?
Is a Notice Regarding Overdraft Fees disclosure required to be posted on an ATM? A question was recently asked about required ATM signage (https://www.bankersonline.com/qa/required-signage-atm) however I did not see mention of this Notice. Could this be a CA specific notice or one that may have been required in the past? The notice reads “If you do not have sufficient funds in your account for the withdrawal amount requested,completing the transaction may result in overdraft fees if you have given us prior permission to complete such transaction….”
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.