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