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How should we disclose a reclearing fee (charged when we send an item back to the payor bank a second time)? – IBA Compliance Connection

How should we disclose a reclearing fee (charged when we send an item back to the payor bank a second time)?

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The Truth in Savings Act (TISA) and Regulation DD require disclosure of a reclearing fee, along with any other fee that might be imposed in connection with the account. 12 CFR 1030.4(b)(4). You should include the amount of the fee or an explanation of how the fee amount will be determined. Id. However, we note that there are serious UDAAP concerns in charging such a fee. If the customer is charged for the second return of the check, even if the check clears, then we believe that this could be considered unfair to customers. Even if the reclearing fee is only charged if the check is returned a second time for insufficient funds, this could be considered a confusing and deceptive practice. Additionally, it could be considered confusing to charge a “reclearing” fee that is the equivalent of a returned check fee, with the only difference being a new name for the fee.