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The FDIC encourages financial institutions to work with affected customers and communities. The FDIC recognizes that such efforts serve the long-term interests of communities and the financial system when conducted with appropriate management oversight and are consistent with safe and sound banking practices and applicable laws, including consumer protection laws. These efforts may include, but are not limited to:
• Reducing or waiving certain fees, such as:
o Automated teller machine (ATM) fees for customers and non-customers,
o Overdraft fees,
o Late payment fees on credit cards and other loans,
o Early withdrawal penalties on time deposits; mobile deposit fees,
• Reduced ACH origination costs for small business
• Waive bill pay fees for consumer or account analysis charges for small businesses
• Increasing ATM daily cash withdrawal limits;
• Easing restrictions on cashing out-of-state and non-customer checks;
• Increasing debit card transaction limits;
• Offering early withdrawal on club plans (i.e. holiday club account funded with tax refund); and
• Allowing early CD redemption without penalties.
• Regulation CC holds
o Emergency conditions
• Regulation D transaction limitations
o Still in effect even through the FRB reduced the reserve requirements to zero.
o Mail/messenger – see 204.2(d)(1) (Example: With proper endorsement these could be used for payments under UCC. E.g. Some assisted living facilities process checks initially payable to resident for payment).
o Fraud – authenticate customer and documentation of that authentication
• Card limit increase
o Both POS and ATM transactions. Also, it should be determined what “balances” the systems is looking at (stand in limits versus a positive balance file) and the impacts of an offline systems.
• The bank should also consider overdraft protection limits, whether static or dynamic as the latter is based on past history and available funds (ability to repay) which could result in significant losses
• FDIC Insurance
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