WASHINGTON (10/6/10)--Credit unions should have the option to list overdraft fees on periodic statements as “total overdraft fees for paid items” instead of “total overdraft fees,” the Credit Union National Association (CUNA) said in a comment letter on the National Credit Union Administration’s (NCUA) interim Regulation DD (Truth in Savings) amendments. Doing so would further distinguish the paid overdraft items from items that are returned unpaid and that are also required to be disclosed, CUNA said. The NCUA, along with the Federal Reserve, last year amended Regulation DD to require all financial institutions to disclose on the periodic statement the fees charged for overdraft services and for returning items unpaid, both for the statement period and the year-to-date. The rule also provides a sample form that may be used to comply with these disclosure requirements, and clarifies some key definitions. CUNA also asked the NCUA to provide credit unions with the flexibility needed to continue using a sample overdraft and returned item fee form. Currently, credit unions would be forced to reformat their disclosures due to minor changes in the NCUA’s form, a situation that would result in additional, unneeded burdens for credit unions. For the full CUNA comment letter, use the resource link.