News & Analysis as of

Overdraft Fees Regulation E

Baker Donelson

Mid-Year 2025 Financial Services Litigation Update

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Litigation against banks and other financial services firms is always evolving. This mid-year 2025 update discusses trends from recent case filings and decisions and highlights the importance of awareness of new legal...more

Cooley LLP

CFPB Issues Final Rule Limiting Overdraft Fees at Large Banks, Treats Overdraft as Credit

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On December 12, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule that treats covered overdraft services offered by banks with more than $10 billion in assets (large banks) as credit, bringing them for...more

Saul Ewing LLP

Big Banks, Beware – CFPB Issues Final Rule to Cap Overdraft Fees

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After nearly a year of speculation, the Consumer Financial Protection Bureau (“CFPB”) issued a final rule (the “Rule”) to cap overdraft fees that financial institutions with at least $10 billion in assets can assess to...more

Ballard Spahr LLP

CFPB issues overdraft rule prior to administration change

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The CFPB has issued its long-awaited final rule that covers overdraft policies at financial institutions with at least $10 billion in assets. The final rule offers those financial institutions three options for designing...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

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

CFPB Issues Guidance Emphasizing the Importance for Banks to Maintain Sufficient Proof of Customers’ Affirmative Consent to...

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In recent discussions surrounding banking practices, the issue of overdraft fees, particularly for ATM and one-time debit card transactions, has gained significant attention....more

Harris Beach Murtha PLLC

CFPB’s Circular 2024-05: Overdraft Services and Their Place in Regulation E’s Opt-In Regime

The Consumer Financial Protection Bureau (CFPB) recently issued Circular 2024-05 (Circular). The CFPB considered whether financial institutions could violate the law by charging fees for providing overdraft services without...more

Nutter McClennen & Fish LLP

Nutter Bank Report: September 2024

The FDIC, OCC, and U.S. Department of Justice (DOJ) have coordinated the release of new policies that will govern each agency’s consideration of bank merger transactions. The FDIC and OCC each published final statements of...more

Orrick, Herrington & Sutcliffe LLP

CFPB warns against collecting on overdraft services without explicit consumer consent

On September 17, the CFPB published a circular clarifying that banks and credit unions can violate the EFTA and Regulation E if they cannot prove that consumers agreed to be enrolled in overdraft services before being charged...more

Ballard Spahr LLP

CFPB Reminds Financial Institutions to Retain Records of Affirmative Consent for Overdraft Opt-in

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On September 17, 2024, the CFPB issued Consumer Financial Protection Circular 2024-05 on improper overdraft practices. The circular reminded financial institutions of their obligation to retain records that prove the consumer...more

Sheppard Mullin Richter & Hampton LLP

CFPB Issues Circular, Curbing Improper Overdraft Fees

On September 17, the CFPB issued a circular stating that financial institutions can be found liable for violating the Electronic Funds Transfer Act by charging overdraft fees if the there is no proof of consumers’ affirmative...more

Troutman Pepper Locke

CFPB Releases New Circular on Opt-In Requirements for Overdraft Services

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On September 17, the Consumer Financial Protection Bureau (CFPB or Bureau) published Circular 2024-05 (Circular) addressing whether a financial institution violates the Electronic Fund Transfer Act (EFTA) and Regulation E by...more

Ballard Spahr LLP

Chopra Delivers Testimony to Congress on Semi-Annual Report

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On June 4, 2024, the CFPB issued its Semi-Annual Report to Congress covering the period beginning April 1, 2023 and ending September 30, 2023. On June 12, 2024, CFPB Director Chopra appeared before the Senate Banking...more

Paul Hastings LLP

CFPB: Fixing Something That’s Not Broken – But Setting Forth a Framework for Abusive Conduct

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The Consumer Financial Protection Bureau (“CFPB” or “Bureau”) recently issued a proposed rule that would prohibit financial institutions from charging nonsufficient funds (“NSF”) fees on instantaneously declined transactions....more

Ballard Spahr LLP

CFPB proposed rule would makes certain overdraft program’s credit subject to Regulation Z disclosure requirements and could cap...

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In furtherance of the Biden Administration’s “junk fee” agenda, on January 17, 2024, the Consumer Financial Protection Bureau issued its proposed rule to amend Regulations E and Z to regulate overdraft services provided by...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

Ballard Spahr LLP

Atlantic Union Bank to pay $6.2M for its unlawful overdraft opt-in practices

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On December 7, 2023, Atlantic Union Bank (the “Bank”) entered into a consent order with the Consumer Financial Protections Bureau (CFPB) related to its in-person and telephone overdraft opt-in sales practices during...more

Hudson Cook, LLP

CFPB Orders Regional Bank to Pay $6.2 Million Related to Checking Account Overdraft Fees

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On December 7, 2023, the CFPB issued an order against a regional bank in Richmond, Virginia. The consent order alleges that the bank charged consumers overdraft fees without getting the proper consent and misled its customers...more

Ballard Spahr LLP

CFPB reported to be planning to unveil overdraft regulations before year-end

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Last week, Bloomberg Law reported that “Consumer Financial Protection Bureau officials have privately told industry executives that the regulator will likely unveil its long-awaited plan to crack down [on overdraft fees] in...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

Ballard Spahr LLP

Delaware federal district court holds use of overdraft notice template did not shield credit union from Regulation E or state law...

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A Delaware federal court has refused to dismiss a class action complaint filed against a credit union that alleges the credit union violated Regulation E and the Delaware Consumer Fraud Act (CFA) even though the credit...more

Troutman Pepper Locke

Delaware Overdraft Fee Decision Highlights Ongoing Compliance Concerns for Opt-In Forms

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On July 19, the U.S. District Court for the District of Delaware issued a decision that should draw the attention for banks that charge overdraft fees for overdraft protection....more

Ballard Spahr LLP

CFPB continues focus on overdraft practices

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In a blog post published last week, the CFPB reported that since the beginning of 2022, it has been collecting data from supervised institutions on their overdraft and non-sufficient fund (NSF) practices and intends to use...more

Hudson Cook, LLP

Current Developments in Bank Deposits and Payment Systems (Spring 2020)

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This survey summarizes several recent developments affecting bank deposits and payment systems. These include payments-related consent orders and enforcement actions by the Consumer Financial Protection Bureau (“CFPB”) and...more

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