[timob1973]

I’m reviewing our periodic statements and I have a question about what fees need to be disclosed. We currently have an account that requires a $10 fee to open. When we open the account, the $10 is deposited into a GL instead of debiting the customer’s account for the fee.

I know under 1030.6(a)(3) that any fee debited from the account must be disclosed on the periodic statement. However, since we don’t debit the customers account for this fee, are we in compliance? Or should we deposit the $10 into the customer’s account and then debit the fee?

My gut says that we are technically in compliance, but I’m concerned about potential UDAAP issues. Any help would be appreciated.

[rcooper]

As long as you are disclosing the account opening fee in the account disclosures I don’t think it will be a UDAAP concern.

[Author]

Posts