We believe that it would be a best practice to disclose the order of posting all transactions, including checks, to consumer customers (this does not necessarily apply to commercial customers). Regulation DD does not require disclosure of the posting order of checks in advertising your overdraft program or in periodic statements. 12 CFR 1030.11. With that said, the FRB (with the other federal banking agencies) has stated that it is a best practice to “[e]xplain impact of transaction clearing policies. Clearly explain to consumers that transactions may not be processed in the order in which they occurred, and that the order in which transactions are received by the institution and processed can affect the total amount of overdraft fees incurred by the consumer.” Interagency Guidance on Overdraft Protection Programs, 70 Fed. Reg. 9127, 9132 (February 25, 2005), Supervisory Letter SR 05-3. Also note that overdraft fees are a very hot topic right now; the CFPB recently launched an inquiry into overdraft fees, which focuses on the order of posting transactions (among other issues).