We agree that you should provide advance notice of an increase in overdraft fees, as Regulation DD requires you to provide advance notice of any change in terms that will adversely affect your customers at least thirty calendar days before the change takes effect. 12 CFR 1030.5(a)(1).

We are not aware of any requirement for providing advance notice when increasing the fee for cashier’s checks. The Official Staff Commentary to Regulation DD states that you do not need to provide advance notice of fee increases for services provided to both account holders and nonaccount holders (such as travelers check and wire transfer fees), nor do you need to provide advance notice of fee increases for “incidental fees” (such as state escheat fees, garnishment or attorneys fees, and photocopying fees). Official Interpretations, 12 CFR 1030, Paragraph b(4), Comment 2. We believe that these exceptions would apply to cashier’s check fees (assuming that service is provided to both account holders and nonaccount holders) and to a safe deposit box drilling fee, which would likely be considered an incidental fee. However, we recommend checking the terms and conditions of your deposit account and safety deposit box agreements to see whether your institution has contractually agreed to provide notices of these fee changes to customers.