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Bounce Protection

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Question: 
We list "bounce protection" as a feature to a few of our accounts. We disclose that customers will be charged a fee for each item paid. During a recent internal audit, it was noted that we must disclose the actual fee amount, which I do not like to do since it dates the brochure. I have read the regulation. No accounts are advertised as free in my brochure. Guidance please.
Answer: 

Go back and read Reg DD section 230.8(f). It states "Institutions that promote the payment of overdrafts in an advertisement shall include in the advertisement the disclosures required by Section 230.11(b) of this part." Your inclusion of the "bounce protection" as a feature would be deemed to be a promotion of the payment of overdrafts. If you look at 230.11(b), you'll find that the very first disclosure item required is the fee or fees for the payment of overdrafts. Your auditor is correct, you have to disclose the actual fee amount as well as the other items listed in 230.11(b).

First published on BankersOnline.com 10/25/10

First published on 10/25/2010

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