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Refund Included Provisional Credit Notice?

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Question: 
When issuing provisional credit to a customer, the customer must be notified within two business days after the provisional credit was given indicating the date and amount of credit. Should the notification include the refund of any NSF fees, or can it simply be the provisional credit of the transaction?
Answer: 

The regulation and commentary indicate that the provisional credit must include any applicable interest. The discussion of making the customer whole as to fees imposed be the bank relates to the final settling up of the claim when your investigation is completed. I believe you can justify postponing the crediting of fees until that time (unless you forget it then). However, some banks prefer to include the fees as part of the provisional credit so that when the final notice is given, it can simply say "your provisional credit has been made final," if that accurately reflects the facts.

First published on BankersOnline.com 9/10/07

First published on 09/10/2007

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