News & Analysis as of

Overdraft Fees Credit Unions

Orrick, Herrington & Sutcliffe LLP

NCUA updates policy on overdraft and NSF fee data collection

On March 3, the NCUA announced changes to its policy on the collection and publication of overdraft and NSF fee income data from credit unions. Previously, the NCUA required federally insured credit unions with assets...more

Ballard Spahr LLP

NCUA Rescinds Policy to Publish Credit Unions’ Overdraft and NSF Income

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Chairman Kyle S. Hauptman announced that the National Credit Union Administration (NCUA) will no longer publish overdraft and non-sufficient fund (NSF) fee income for individual credit unions with more than $1 billion in...more

Troutman Pepper Locke

NCUA Releases its 2025 Supervisory Priorities

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On January 7, the National Credit Union Administration (NCUA) released its supervisory priorities for 2025, outlining the key areas of focus for federally insured credit unions. This guidance is crucial for credit unions as...more

Brownstein Hyatt Farber Schreck

CFPB Finalizes Controversial Overdraft Overhaul

On Dec. 12, the Consumer Financial Protection Bureau (CFPB) finalized a controversial rulemaking that would fundamentally alter how banks and credit unions offer overdraft services. The proposed rule was issued in January...more

Sheppard Mullin Richter & Hampton LLP

CFPB Release Final Rule on Overdraft Fees

On December 12, the CFPB released the final version of its overdraft rule that was first proposed in January. (We discussed it here.) Currently, financial institutions that extend overdraft protection are exempt from certain...more

Troutman Pepper Locke

NCUA Issues Guidance to Federal Credit Unions on Overdraft and NSF Fee Practices

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On December 10, the National Credit Union Administration (NCUA) issued a letter to all federally insured credit unions, highlighting the risks associated with certain overdraft and non-sufficient funds (NSF) fee practices....more

Goodwin

CFPB Enters Into $95 Million Consent Order with Credit Union to Resolve Allegations of Improper Overdraft Fee Practices

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​On November 7, 2024, the CFPB ann​ounced​​ that it had entered into​ a consent order with a major credit union​​ resolving ​allegations that the credit union improperly assessed overdraft fees against consumers​​. The credit...more

Sheppard Mullin Richter & Hampton LLP

CFPB Imposes $95 Million Fine on Large Credit Union for Overdraft Fee Practices

On November 7, 2024, the CFPB ordered one of the largest credit unions in the nation to pay over $95 million for its practices related to the imposition of overdraft fees. The enforcement action addresses practices from 2017...more

Kaufman & Canoles

Be Warned: Defendant’s Motion to Dismiss Overdraft Fee Claims Denied

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Claims of unfair overdraft fees continue although it seems the media has taken a break from talking about them. A recent federal case in Virginia ruled in favor of all the Plaintiff’s counts and denied the Defendant’s Motion...more

Goodwin

California Attorney General Warns California-Chartered Banks and Credit Unions On Surprise Overdraft Fees and Returned Deposited...

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On February 20, 2024, California Attorney General Rob Bonta issued a letter warning California-chartered banks and credit unions with assets under $10 billion that charging surprise overdraft fees and returned deposited item...more

Cozen O'Connor

Show Me the Money: AG Bonta Warns California Small Banks and Credit Unions Against Surprise Fees

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California AG Rob Bonta issued letters to small banks and credit unions warning that overdraft and returned deposited item fees likely violate the state’s Unfair Competition Law and the federal Consumer Financial Protection...more

Ballard Spahr LLP

California AG issues warning to state-chartered banks and credit unions on “surprise overdraft” and returned deposit item fees

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On February 22, 2024, California Attorney General Rob Bonta issued letters (the “AG Letter”) to California’s 197 state-chartered banks and credit unions warning that overdraft and returned deposited item fees may violate...more

Ballard Spahr LLP

Credit unions should expect increased supervision from NCUA on overdraft/NSF fees, vendor risk, and fair lending

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On February 6, 2024, National Credit Union Administration (NCUA) Chairman Todd M. Harper spoke at a Brookings Institution event to outline his regulatory agenda and supervisory priorities for 2024. His prepared remarks...more

Brownstein Hyatt Farber Schreck

CFPB Targets Banks and Credit Unions in Controversial Overdraft Proposal

The Consumer Financial Protection Bureau (CFPB) released a long-anticipated notice of proposed rulemaking on Jan. 17 that would fundamentally alter how overdraft services are provided by banks and credit unions. The CFPB is...more

Ballard Spahr LLP

CFPB issues report to bolster its imminent overdraft and NSF fee rulemaking

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As we await the CFPB’s proposed overdraft and nonsufficient funds (NSF) fee rule, the CFPB issued another report, Overdraft and Nonsufficient Fund Fees: Insights from the Making Ends Meet Survey and Consumer Credit Panel. It...more

Holland & Knight LLP

Mandatory Arbitration and Class Action Waivers by Amendment: Easier Said Than Done

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In response in part to the dozens of cases filed throughout the country related to assessment of insufficient funds (NSF) and overdraft (OD) fees, many banks and credit unions have sought to add arbitration and class action...more

Hudson Cook, LLP

CFPB Bites of the Month - October 2023 - Bewitching the CFPB

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In this month's article, we share some of our top "bites" for the prior month covered during the October 2023 webinar. Bite 10: New Report on NSF Fees at Banks and Credit Unions On October 11, 2023, the CFPB issued a data...more

Husch Blackwell LLP

Federal Court Allows Class Action on Deposit Account Fees to Proceed

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A New York federal court has largely denied a state credit union’s motion to dismiss a class action lawsuit regarding non-sufficient funds (NSF) fees, overdraft fees, and out-of-network ATM fees. See Fairchild-Cathey v....more

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights: V 3, Issue 1, January 2023

Plaintiffs Pursuing Increased Class Action Breach of Contract Claims for Overdraft Fees and Charges Against Customers - “With plaintiff attorneys seeing potential large dollar settlements and verdicts, along with increased...more

Cadwalader, Wickersham & Taft LLP

Regulation E Model Forms May Not Always Be a Safe Harbor

In an opinion written by U.S. District of Delaware circuit judge Stephanos Bibas that begins, “A good template serves as a guide, not gospel,” Del-One Federal Credit Union was denied the safe harbor typically proffered by use...more

McGlinchey Stafford

Is My Electronic Signature Valid? - Commercial Law Bulletin - June 10 2022

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Ohio- Uniform Trade Secrets Act Sal’s Heating & Cooling, Inc. v. Bers Acquisition Co., 8th Dist. Cuyahoga No. 110685, 2022-Ohio-1756- In this appeal, the Eighth Appellate District affirmed the trial court’s decision,...more

Burr & Forman

Eleventh Circuit Affirms That Banks Must Use Unambiguous Language When Disclosing Methods For Assessing Overdraft Fees

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In Carol Tims v. LGE Community Credit Union, the Eleventh Circuit Court of Appeals held that a credit union’s account agreement with one of its customers was ambiguous about which account balance calculation the bank would...more

Miller & Martin PLLC

Class Actions Based on Overdraft Fees on the Rise

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As a word of caution, the plaintiffs’ bar is filing a wave of class actions against credit unions and banks based on the assessment of overdraft fees. Some cases challenge practices, such as high-to-low sequencing of...more

Dorsey & Whitney LLP

Mulvaney-Led CFPB Actively Litigates in Court Regarding Overdraft Policy-Related Evidence

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Many observers have reported on leadership changes at the Consumer Financial Protection Bureau (“CFPB”) and the potential shifts in policy priorities that may follow. However, in the new year, among the most interesting...more

Carlton Fields

Third Circuit Permits Limited Discovery On Issue Of Validity Of Arbitration Agreement

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In an unpublished opinion, the Third Circuit affirmed a decision denying a defendant bank’s motion to dismiss a consumer complaint in favor of arbitration when the contract containing the arbitration clause was not referenced...more

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