There is a saying, "People are slow learners but fast forgetters." The longtime alternative to offering ODP to bank customers is simply to bounce checks and collect NSF fees. The downstream harm to bank customers can be enormous, including possible criminal prosecution for issuing bad checks. Moreover, the CFPB has no authority whatsoever to impose price controls, particularly under the risible assertion that consumers will "save" money. Watch while depositories raise minimum deposit requirements, charge more for basic account services, and make checking accounts less accessible to LMI customers.
A new rule released today caps overdraft fees to $5 for large banks, absent treating them like loans with APY disclosures, according to American Banker. "Under the final rule, large banks can cap their overdraft fees at $5, a level commensurate with what the CFPB estimates would be necessary to cover the service's cost to banks. Alternatively, banks can cap their fees at an amount that covers costs and losses, rendering overdraft a "convenience service rather than a profit center." #Overdraft has long been under scrutiny by the CFPB, with increasing limitations on the amount of fees that can be charged in single day, strong suggestions regarding the use of de minimis fees, and overdraft protection becoming a target for #UDAAP findings. For those who offer #overdraft services or charge NSF fees, an uptick in class action lawsuits tied to disclosures has caused them to reconsider the offering of the functionality altogether, with potential consequences to consumers who may rely on the float. It will be interesting to see how many more #financialinstitutions may choose to opt out to avoid increased risk if the rule avoids legal challenge and later repeal. https://lnkd.in/dXUXFf3R #regulatorychange #compliance #banking #fintech
Former Senior Vice President, General Counsel at National Retail Federation
2 个月Would anyone object to airlines charging a fee to let families sit together ?