In 2022, the FDIC issued guidance that re-presented unpaid transactions, commonly referred to as NSF items, should NOT be subject to an NSF charge if the bank assessed a fee the first time the item was presented for payment. The practice of charging a fee the second time has been considered “consumer harm” and deceptive by the FDIC.
Peak’s Deposit and RPA consultants recently assisted a bank on a project to identify already returned items that are now being re-presented. An RPA script was built to run daily against system reports to identify any previously returned items. The re-presented items were kicked out on an exception report for the bank to review allowing them to stay within the FDIC guidance and avoid charging multiple fees for the same item. The bank was pleased with how quickly the solution identified these items: “This is amazing, and we are making the adjustments and removing the second fee. Thanks for all your work on this, I can’t wait to keep going with other projects.”
For more information on this project, contact Brandy Nielson at brandy@peakconsultingllc.com.
