Regulatory Alerts2026-04-10 | FIL-14-2026FDIC Rescinds Supervisory Guidance on Multiple Re-Presentment NSF Fees
The FDIC immediately rescinds Financial Institution Letter 32-2023, which previously provided supervisory guidance on how supervised institutions assess multiple non-sufficient funds fees from re-presented transactions. The regulator determined that the prior guidance was overly broad and created uncertainty regarding potential unfairness claims under Section 5 of the Federal Trade Commission Act. Supervised financial institutions must now ensure their consumer disclosures accurately reflect actual practices and comply with all applicable laws, regulations, and legal requirements.
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