We currently offer two overdraft protection options - one is a transfer from a line of credit and the other is an auto transfer from a deposit account. In either case, we have a disclosed transfer fee of $5.00 per transfer which is charged to the checking account regardless of whether the funding account is the LOC or the deposit account. We would like to increase the fee on existing accounts. Because we charge the same fee (whether it is a LOC transfer or a deposit account transfer) to the checking account is it possible to increase the fee with a 30 day notice to customers like any other fee adjustment? We are also considering an annual fee for this service for both new and existing customers. The annual fee would be charged to the checking account and not to the LOC/funding account.
We are looking to combine 3 of our current checking accounts into a new type of excellent checking account that offers the customer lots of perks. What kind of disclosures and notices are we required to present to our current account holders of these 3 accounts before, during and/or after this process?
We are looking to change (strengthen) the penalties on CD maturities - what type or time frame of notice do we have to provide for those changes going forward?
Regulation DD (12 CFR 1030.8)
Institutions who advertise "free" checking accounts only for a limited period of time may be advertised as free if the time period is also stated.
My institution is currently advertising a checking account as "free" for ages 16 to 23, specifying those under 18 years of age require joint ownership with parent or guardian. Offer valid through 12/31/14.
Does the fact that a time period is not stated constitute a Regulation DD violation?
I have had the interesting experience of traveling around the country during the past few weeks running workshops and seminars on the new Truth-In-Savings regulation, Reg. DD.