Deposit Account Services & Fees
Any fee associated with deposit products and services offered in connection with meeting consumer needs is fully disclosed and accepted by the customer, thus creating a contractual obligation between the customer and community bank.
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Position & Background
ICBA strongly supports a consistent legal and regulatory framework for deposit account services and deposit-alternative accounts (e.g., prepaid cards) that gives community banks flexibility to provide a variety of services to meet consumers’ financial needs and affords non-bank consumers the same transparency and protections bank customers receive.
ICBA opposes any requirements that would dictate a community bank’s deposit account screening and/or closing procedures.
ICBA broadly opposes restrictive price controls and caps imposed by any regulatory agency and believes that such intervention only distorts market discipline and demand for delivery of products and services.
Restrictions on deposit account fees have a negative ripple effect on customers and businesses that rely on these services. Community banks are prohibited by laws and regulations from assessing, or “surprising” consumers with fees without fully disclosing them.
Community banks offer many deposit account services to best address consumer needs. These include a variety of programs and alternative services that allow customers to transfer funds from a designated account or line of credit or to advance funds from a short-term, small-dollar loan to ensure sufficient funds and avoid overdrafts. Any fee for a deposit product or service offered in connection is fully disclosed and accepted by the customer, creating a contractual obligation.
Over the last several years, a variety of e-commerce transactions have been created which may cause overdrafts, non-sufficient funds, and other fees. In addition to ATM and POS debit transactions, these included online and mobile POS transactions. Community banks have continued to expand the features of payment programs and options they provide to consumers.
It is in the consumer’s best interest for their bank to pay items/transactions rather than reject them and trigger various payee fees levied by merchants, utilities, landlords, and other creditors. In particular, when a customer has scheduled automatic, recurring debit payments, restrictive rules may trigger a spike in declined or rejected transactions which are costly to merchants and customers.
Letters & Testimonies
Joint Letter Opposing Affirm Bank’s Application for Deposit Insurance
ICBA Expert Contacts
