Consumers are handling more and more of their transactions electronically and the payment and processing systems used by our industry are becoming increasingly complex. This combination of factors has led to a rise in accountholder confusion as to exactly when payments will be made from their accounts.
In the Winter 2014 issue of its publication, Supervisory Highlights, the CFPB provided a lengthy dissertation on balance definitions in the calculation of fees for debit card transactions and disclosures. In it, the CFPB has made it clear that certain debit holds may not be used in considering NSF charges unless properly and very clearly disclosed.