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Fair treatment with fee rebates

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Question: 
Our regulators asked us for our procedures for waiving overdraft fees. What are they looking for?
Answer: 

Since an overdraft is an extension of credit and charging different fees based on prohibited basis would violate Reg B, examiners are evaluating if there is any disparate treatment in rebating overdraft fees. For example, if the institution disproportionately denies fee rebate requests for protected classes, there could be fair lending risks even through overdrafts are usually considered as part of a deposit product review.

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Learn more about Brian Crow’s webinar The Maze of Overdraft Compliance

First published on 10/04/2020

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