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Category Archives: Deposit Accounts

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CFPB releases white paper on overdraft programs

By Jeremy T. Rosenblum on 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

By Barbara S. Mishkin on 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

By Keith R. Fisher on 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

By Jeremy T. Rosenblum on 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?

By Barbara S. Mishkin on 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

By Jeremy T. Rosenblum on 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

By Jeremy T. Rosenblum on 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

By Barbara S. Mishkin on 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 >