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We have a fee listed in our deposit disclosure booklet called ACH revocation/stop payment. We have never charged the fee for ACH revocations before but we have always charged for the stop payment. We now would like to start charging the fee for the revocations. The fee would be listed on the statement as “ACH revocation”. Our CSRs are to inform the customer that we will now be charging $30 for the revocation at the time they are filling out the form.
Since the fee has already been disclosed in our disclosure booklet, do we need to notify our customers 30 days prior to charging the fee? Is this merely a customer service issue where it would be nice to tell them ahead of time or is there a regulatory issue as well?
Is this a UDAAP issue?
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