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.
David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transform the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM), and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have 3 adult children and 2 grandsons (none of whom live at home!) and 3 cats (of which Dave is allergic … the cats, not the children!). They live on a lake in Nebraska and when possible he can be found fishing or making sawdust in his shop. David plays the guitar & piano and enjoys singing with Karen. They occasionally lead worship at their church.