TISA Overdraft Fees
By David Dickinson
The Federal Reserve Board recently issued clarification about TISA's requirement to list month-to-date and year-to-date overdraft fees on periodic statements. The memo:
- Indicated the term "Total Overdraft Fees" is required when disclosing such fees on periodic statements (effective October 1, 2010).
- Clarified that when disclosing balance information through automated systems for retail sweep accounts, the regulation does not require an institution to exclude funds from the consumer's balance that may be transferred from another account pursuant to a retail sweep account program.
- Stated when listing overdraft fees and returned item fees in the required table on periodic statements, the table should have internal lines to distinguish rows and columns. The FRB provides the following illustration:
| Total for this period | Total year-to-date | |
| Total Overdraft Fees | $60.00 | $150.00 |
| Total Returned Item Fees | $0.00 | $30.00 |
The FRB also issued updated exam procedures for Regulation DD. You can find them here.