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Change in Overdraft Fee - Notification Method

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Question: 
We are increasing our overdraft fee. Can I notify my online customer with a simple banner to click on? If not, can I send them an email, or do they need it delivered via snail mail?
Answer: 

Overdraft fees are required to be disclosed in writing under Regulation DD. You must advise your consumer customers of a fee change in writing, at least 30 days before it goes into effect. It can be on a statement, a statement stuffer or in a separate mailing. It can be delivered electronically if you and the customer have "done the E-SIGN dance" and you have the customer's demonstrable consent to electronic notification. A banner notice on your online banking site would be the equivalent of posting a notice in your customer lobby. It won't satisfy the regulatory disclosure requirement.

First published on BankersOnline.com 2/7/11

First published on 02/07/2011

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