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Category Archives: Deposit Accounts

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CFPB Explores Checking Account Screening Policies and Practices

Posted in Deposit Accounts

Today, the CFPB held a forum to learn more about how consumers are impacted by checking account screening policies and procedures. The CFPB recognizes that checking accounts are one of the most widely used financial products by consumers, but the CFPB has expressed concerns that screening practices may be preventing consumers from gaining access to… More >

CFPB releases more overdraft program data as a prelude to likely rulemaking

Posted in Deposit Accounts, Overdrafts

The CFPB moved closer to likely rulemaking on overdraft programs with the release late last week of a new report entitled “Data Point: Checking account overdraft.”  The report is based on account-level and transaction-level data for about two million accounts at large banks covered by the CFPB’s supervisory authority (i.e., banks with more than $10 billion… More >

Industry trade group seeks higher asset trigger for new requirement to report overdraft and other consumer deposit account service charges

Posted in Deposit Accounts

The Independent Community Bankers of America (ICBA) wants to limit the application of a new Call Report requirement for banks to include a breakdown of their income from service charges on consumer deposit accounts.  In a notice published in the Federal Register on January 14, 2014, the Fed, FDIC and OCC (Agencies) announced that they are… More >

CFPB calls for public disclosure of campus financial product marketing agreements

Posted in Credit Cards, Debit Cards, Deposit Accounts, Prepaid Cards

The CFPB wants financial institutions to post on their websites their marketing agreements with colleges and universities for financial products other than credit cards, such as deposit accounts, prepaid cards and financial aid disbursement accounts.  Pursuant to the CARD Act, card issuers must submit their campus credit card agreements annually to the CFPB together with… More >

ABA makes suggestions to CFPB for overdraft study

Posted in Deposit Accounts

The American Bankers Association has sent a letter to the CFPB responding to the CFPB’s June 2013 white paper reporting its initial data findings on overdraft programs. When the paper was issued, we observed that regulation by the CFPB seemed likely and commented that it would require considerable thought and creativity for the CFPB to… More >

CFPB findings on campus banking products portend new limitations

Posted in Debit Cards, Deposit Accounts, Prepaid Cards, Student Loans

Findings on campus banking products released this past Monday by the CFPB in conjunction with a Banking on Campus Forum held in Washington, D.C. appear to be a harbinger of new limitations on the marketing of these products.  The findings were based on comments the CFPB received in response to a January 2013 notice seeking input on… More >

CFPB to hold September 30 forum on financial products marketed to college students

Posted in Credit Cards, Debit Cards, Deposit Accounts

On September 30, 2013, the CFPB will hold a forum in Washington, D.C. on financial products marketed to college students.  In January 2013, the CFPB issued a notice asking for input on a variety of issues with regard to these products, including the information shared between schools and financial institution providers, the way these products are… More >

CFPB releases white paper on overdraft programs

Posted in Deposit Accounts

Yesterday, just after midnight, the CFPB released its initial data findings from its 15-month (and counting) Study of Overdraft Programs.   In a welcome departure from its April white paper on payday and deposit advance loans, the overdraft white paper is entirely devoid of a hostile tone, attacks on the industry or prejudgments on the basis… More >

CFPB action on overdraft fees not imminent

Posted in Deposit Accounts

Despite expectations that the CFPB would make overdraft fees a priority item, it appears that new overdraft rules or other CFPB action is not on the near horizon.  According to a report today by Carter Doughtery in Bloomberg News, CFPB Director Richard Cordray, in a conference call earlier this month with credit unions, indicated that… More >

With Bi-Partisan Support, Senate Banking Committee Chairman Introduces Bill Combining ATM Fee Notice and CFPB Anti-Privilege Waiver Provisions

Posted in CFPB Exams, Deposit Accounts

On Tuesday July 17, Senate Banking Committee Chairman Tim Johnson (D.-SD) introduced a new bill, S. 3394, which combines two consumer-related regulatory initiatives that had already been separately introduced and passed by the House of Representatives.  These are (1) eliminating one of the automated teller machine (“ATM”) fee notice provisions (so-called “ATM placard regulation”), passed… More >

“Penalty box” redux

Posted in CFPB Rulemaking, Deposit Accounts, Hot Issues

One of our favorite readers commented on the CFPB’s overdraft “penalty box,” which was the subject of a prior blog.  Our reader criticizes the CFPB for creating the impression that the concept of an overdraft fee box is new.  In fact, Reg DD currently requires a (shorter) box that lists the amount of overdraft and… More >

CFPB expands complaint system: who forgot to tell Director Cordray?

Posted in Deposit Accounts, Student Loans, Vehicle Loans

In a blog post appearing today on the CFPB’s newly redesigned website, Director Cordray announced that the CFPB is now taking on-line complaints about deposit accounts. According to Director Cordray’s blog post (and the CFPB’s press release about the expansion), the only other complaints currently being taken by the CFPB are credit card and mortgage loan… More >

Deposit advance loans under attack

Posted in CFPB General, CFPB Rulemaking, Deposit Accounts, Payday Lending

Coincidentally (or not), on the same day the CFPB launched its overdraft fee initiative, previously discussed, 250 national, state and community organizations and individual activists wrote the heads of the CFPB and the federal banking agencies to attack deposit advance products. Both the CFPB in its payday lending exam manual and the authors of this letter… More >

CFPB overdraft fee initiative threatens to put banks in a penalty fee box

Posted in CFPB General, CFPB Rulemaking, Deposit Accounts, Hot Issues

Last week, Barbara Mishkin posted generally on the CFPB’s overdraft fee initiative. I found the CFPB’s prototype “penalty fee box” particularly interesting and have a few comments:  While it is certainly possible that the CFPB will both require targeted disclosures and sharply circumscribe consumer choice, I take some hope from the penalty fee box disclosure that… More >

Overdraft fees take a front seat

Posted in Deposit Accounts

Since the CFPB was launched, we have been predicting that overdraft fees would be among the CFPB’s priority items. With the CFPB’s announcement today that it has launched an inquiry into checking account overdraft programs, it’s clear our predictions were correct. The CFPB’s focus on overdraft fees is proceeding on several different fronts and we… More >