Internal Compliance Notes
UNFORMATTEDNSF / overdraft fee change — need customer notice ASAP
- Old NSF fee: $35 per item
- New NSF fee: $25 per item (going down, so that's good right?)
- Old overdraft transfer fee (linked savings): $10 per transfer
- New overdraft transfer fee: $0 (eliminating it entirely)
- Effective date: August 1, 2026
- Applies to: all personal checking accounts (Summit Checking, Flex Checking, Student Checking)
- Business accounts NOT affected
- Channel: mailed notice + email + in-app message
- Legal says we definitely need to send something compliant
— mentioned "Reg DD? Reg E? not sure which one applies here"
— also not sure how many days in advance we need to send it
- Marketing wants to spin the fee reduction as a positive story
- Need a checklist of what has to be in the notice so legal can sign off
- Also need to know: do we need member consent or just notice?
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Plain-Language Customer Notice
Required Elements Checklist
| Required Element | Status |
|---|---|
| Clear identification of account type(s) affected | INCLUDED ✓ |
| Old fee amount and new fee amount, stated clearly | INCLUDED ✓ |
| Effective date of change | INCLUDED ✓ |
| Plain-language description of the nature of the change | INCLUDED ✓ |
| Right to close account before effective date (Reg DD) | INCLUDED ✓ |
| Institution contact information for questions | INCLUDED ✓ |
| Opt-in / consent language for overdraft coverage (Reg E) | VERIFY — fee reduction; no new consent needed, but confirm opt-in disclosures reference updated fee amount |