As a public citizen invited to comment by the FDIC, here are a few suggestions.
Firstly, consistency and written rules must be implemented rather than each auditor using his opinion of a violation.
The rules of the department of Motor vehicles is a good example such as, the speed limit on this freeway is 55 miles per hour.
The time of day, traffic conditions and day of the week is not taken into consideration.
They should be applied to rules such as a bounced check is charged $30.00 for each presented.
On any given day, where there is not enough collected funds in the account, the lowest dollar amount of each check will be paid first.
Charges will then be levied on each remaining check that could cause an overdraft thereafter.