Comment on the CFPB’s Notice of Proposed Rulemaking on Overdraft Fees for Very Large Institutions
CRL submitted a comment on the CFPB’s Notice of Proposed Rulemaking on overdraft fees for very large institutions. We advocate for a $6 benchmark and safe harbor for courtesy overdraft fees. We argue the proposed rule is a required and important step towards better protecting consumers that would be greatly improved by eliminating the potential for financial institutions to evade the intent behind the exemption by further narrowing it to include parameters on: (1) limitations on the frequency and total number of overdrafts, (2) precluding fees for de minimis overdraft amounts, and (3)...