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Charging Fees on Employee Overdrafts

Question: 
What is the rule on charging OD fees on employees overdrafts?
Answer: 

Answer by Randy Carey: Unless governed under State law, it would be left to the Bank's discretion.

Answer: 

Answer by John Burnett: Assuming that you are using the term "employee" broadly, take into account that, if the employee is an executive officer of the bank, Federal Reserve Board Regulation O Section 215.4(e) restricts the payment of overdrafts, and the executive officer must be subject to the same fee charged any other customer of the bank in similar circumstances.

Answer: 

Answer by Randy Carey: Of course you are correct John. However, if we use the term employee "really broadly," then we should clarify that those prohibitions also apply to an executive officer or director of the bank or executive officer or director of its affiliates.

First published on BankersOnline.com 1/7/13

First published on 01/07/2013

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