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June 16, 2010

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Tim Kolk

I'd encourage keeping in mind three more related items:
1) You can only charge for one penalty event, so if a bounced check results in a late payment you cannot charge an NSF and Late Payent fee...that's a systems headache to program, to be sure.
2) The rules also appear to prohibit annual fees that are waived if an account is used enough(e.g. 6 charges in a year). This tries to close a back door way to assess 'inactivity fees' but may catch many credit unions unaware.
3) If you merge in a credit union with a credit card portfolio you have to track the 'acquired' accounts that were repriced in the past as if they were your own. If you cannot identify them you have to treat ALL of the merged-in accounts as having been repriced and require tracking and possibly rate reductions.

Much more in the details, but these are my 'top 3 issues' for small issuers.

Diane Hatcher

I bet annual fees will be back. And maybe even some newly made up fees.... Card production fee, statement mailing fee, etc.

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