Regarding the following question I read today, would it be okay for a bank to charge the overdraft fee if the customer HAD opted in - even though the
account had a positive balance when the transaction was approved? Or, does this fall in line with the UDAP statement from the agencies?
Can we charge an overdraft fee for a one-time debit card transaction that overdraws an account of a customer who has not opted-in if there were
sufficient funds at the time of authorization but not at the time the transaction posts?
No. The rule does not include any exceptions for card transactions that overdraw an account. The rule at its simplest is, "No opt-in, no overdraft
What is your opinion of offering a checking account that offers add-on third party benefits as a feature of the account? Customers are only able to obtain the add-on services if they buy the account and pay the service charge disclosed for this product.
Does UDAAP apply to just consumers, or all customers?
You instruct people to listen carefully for deceptive answers before releasing information. Can you provide me with an example of a deceptive answer that a staff member might accept from a social engineer?
We are revising our deposit accounts and one account will be titled Free Checking. This product will have e-statements as the default at no charge. Since e-statements are the default, we will charge $3.95 for a paper statement. Is this a concern relative to Unfair, Deceptive, or Abusive Acts or Practices?