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If the bank advertises an overdraft program as free, does that include any fees, or just those directly related to the overdraft?
Advertising materials must disclose all fees, costs or penalties that may be imposed consistent with Regulation DD advertising. UDAAP is concerned whether there is harm including monetary harm to the consumer. Monetary harm may include costs and fees. The UDAAP examination manual provides additional information on what harm to the consumer means.
Reference: Regulation DD: 12 CFR 1030.8 and 1030.11(b) CFPB, UDAAP exam manual, version 2 October 2012, page 2