[knifleygirl]

We want to offer a free checking account and noticed that on our universal fee sheet we have a fee listed for phone transfers. Would this affect our ability to offer this free account?

[rcooper]

I think it would affect your ability to call the account free. Regulation DD, 1030.8 states the following fees charged to account prohibit it from being called free or no cost.

Commentary Section 1030.8 –Advertising
“(a) Misleading or inaccurate advertisements.

3. Fees affecting “free” accounts. For purposes of determining whether an account can be advertised as “free” or “no cost,” maintenance and activity fees include:

i. Any fee imposed when a minimum balance requirement is not met, or when consumers exceed a specified number of transactions.

ii. Transaction and service fees that consumers reasonably expect to be imposed on a regular basis.

iii. A flat fee, such as a monthly service fee.

iv. Fees imposed to deposit, withdraw, or transfer funds, including per-check or per-transaction charges (for example, $.25 for each withdrawal, whether by check or in person).”

Assuming you meet the other requirements you could eliminate this fee for this account.

[Author]

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