FDIC Guidance on Multiple Representment Fees
By now, you’re likely well aware that the FDIC has been citing institutions when examiners do not believe it’s clearly disclosed that multiple NSF fees may be charged if an item is presented multiple times. The FDIC has found this to be a deceptive and, in some cases, also an unfair practice if customers are not given the opportunity to avoid multiple fees being charged.
The FDIC has now given some Guidance outlining the related Compliance, Third-Party, and Litigation Risks and potential ways to mitigate those risks. The Guidance lays out the FDIC’s expectations for institutions if/when an issue is self-identified. It also gives an overview of the FDIC’s approach when issues have been self-identified and fully corrected versus when they have not been.
Keep an eye out for our September Magazine, where we’ll address the Guidance in more detail! Also, be sure to join us for our webinar, “Deposit Operations Overview." We will discuss this issue and a wide variety of deposit-related compliance requirements!
Published
2022/08/22
Diane Dean
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients. Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!