Filed under: Truth in Savings Act | Tags: compliance, overdraft services, small credit unions, Truth in Savings
As part of getting ready to record tomorrow’s CIiCU #39, I was talking to the group about potential topics for the show. Hal Scoggins mentioned the NCUA Final Rule on Truth in Savings (with a shout out to Register Lady for making this easy to find). The terrific part about CIiCU for me is that I often hear about things that I miss. That was certainly the case here.
Now I am familiar with what has been happening with overdraft services and I knew what was being proposed. We’ve talked about it here previously.
The bottom line is that NCUA is requiring “all credit unions to disclose periodic and aggregate overdraft fees on periodic statements regardless of whether they advertise or promote member use of overdraft services.” As a side note, NCUA feels that the 3,335 small credit unions that it identifies in this Rule should not be impacted significantly in an economic way. It strikes me that if these small credit unions have to stop offering overdraft services because they cannot comply with the rule, that the impact will indeed be significant!
The effective date is January 1, 2010, which, incidentally, is a date picked by one of the credit unions that wrote into NCUA to express a comment. This goes to show that it pays to comment on proposed rules!