Institutions that don't advertise (in the new, broader sense of the word) a "convenience overdraft protection service," have three areas of concern in the TISA regulation amendments:
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- Check your account disclosures to be sure that your description of when overdraft charges may be assessed is adequate given the new Comment #5 under Fees in the Commentary to section 230.4.
- If you charge a fee when you pay an overdrawn item and charge a fee when you return an overdrawn item, make sure you don't call those two fees the same thing. They are supposed to be separately named. That can affect both account disclosures and statement printing.
- Make sure, if you are advertising "free accounts," that you don't mention an account-related service (such as bill pay) that isn't free unless you make it clear there's a fee for that service.
First published on BankersOnline.com 6/12/06