Under Regulation E (Electronic Fund Transfer Act), if a bank determines that an error occurred, it must correct the error, including the crediting of interest and fees, when applicable. (Commentary to §1005.11(c)-6)
Q Is it acceptable to list the fees and interest refunded as one lump sum, or must the fees and interest be itemized?
A The regulation does not explicitly require that these refunds be itemized. The institution must ensure that the total amount refunded includes all applicable fees and interest charges, but it can provide this as a lump sum.
That said, providing an itemized breakdown of the refunded amounts can enhance transparency and help the customer understand the correction. This practice can also serve as a good record-keeping measure for the institution.
For absolute certainty and to ensure compliance with your institution’s policies, it may be advisable to consult with your prudential regulator or review your institution’s specific procedures regarding error resolution under Regulation E.
For more information, contact ABA’s Leslie Callaway.
Please note that this section is not a substitute for professional legal advice.
