Helena Community Credit Union

April 17, Attn: [redacted] Response to complaint from [redacted] and [redacted] - Acct [redacted] Dear Mr [redacted] ; In researching [redacted] ’s claim we have found all fees charged to her account were in compliance with our Privilege Payment (ODP or Courtesy Pay) program policies which are compliant with both state and federal regulations Additionally we have gone to great lengths to help [redacted] understand how this program works in order for her to avoid such fees in the future The credit union has reversed $in Privilege Pay fees since January of as an accommodation to assist her financially while providing valuable education about how our ODP program is to be used Our goal is to facilitate financial independence for [redacted] and the appropriate use of our products and services Ms***’s complaint, as we understand, is that she is assessed fees based on her perception of what her account balance is In reviewing the account transactions, the member uses the debit card for most purchasesWhen the member is looking at the account balance online there are two balances showing, the ‘ledger balance’ and the ‘available balance’ which is confusing The available balance is the ledger balance less funds being held for items purchased with the debit card but not settled for payment The member has the ability in online banking to see what transactions are holding funds against the ledger balance When a member uses their debit card they can choose to process the transaction as PIN based purchase or as a signature based purchase If the member chooses a PIN based transaction, the transaction amount is immediately withdrawn from the account in real time If the member chooses a signature based transaction, the merchant requests an authorization for approval which places a hold for the transaction amount against the account balance thus reducing the available balance A hold can last up to business days but will expire when the matching transaction posts The transaction doesn’t post to the member’s account until settlement occurs The settlement of the transaction is controlled by the merchant and when they batch their transactions Batching usually happens within two or three business days of the purchase, but per regulation the merchant has up to months to present the transaction for payment If the member is using the online “ledger balance” to determine how much [redacted] they have, it will not show any uncleared (or unpresented) checks written or the amounts authorized and held for payment to the merchant When a member is relying on the online balances versus keeping a check register of their spending, they may overdraw their account Even though the amounts haven’t physically cleared the account the funds have already been spent All member accounts in good standing are qualified for “Privilege Pay” which allows them to overdraw the account up to $ If the member overspends what they have available, Privilege Pay will overdraw the account and pay the item saving the member the embarrassment of having items returned NSF Members can choose to not have access to Privilege Pay by opting out of the program If a member does not have Privilege Pay, debit items that would overdraw the account are not authorized and insufficient checks written are returned as NSF with a fee However, when Privilege Pay is accessed to pay amounts greater than the available balance in the account, a fee is assessed On 11/2/the member spoke with an employee in our call center about her overdrawn account and the fees assessed on checks written The employee explained that the member had three pending debit transactions that were holding the funds and there weren’t monies available to clear the items without using the Privilege Pay program While the members have had access to privilege pay for a number of years, they did not Opt In for the Reg E portion of Privilege Pay until November Prior to 11/15/the member was unable to overdraw her account using a debit card because purchases without available funds could not be authorized at the merchant level On 11/15/the member contacted the credit union because a debit transaction she was trying to process was being denied At that time the member requested to be optfor Reg E so that the transaction would be approved The member has not revoked that opt in When debit transactions clear the account there may be a Privilege Pay fee charged if other transactions debit the account while the card authorization is holding funds against the available balance In addition to Privilege Pay, the credit union has a my!points program that rewards members for loyalty Points are rewarded for loan interest paid, dividends earned and debit card usage Points can be redeemed to refund a portion of fees assessed, lower interest rates on loans and increase certificate rates The credit union policy only allows two fee refunds per month In reviewing the notes on the member’s account, the credit union has refunded fees on a number of occasions using the my!points program and when she didn’t have points available exceptions were made In December 2013, the member was having similar issues with fees on the account She met with one of our member service staff who explained how the Privilege Pay program workedAs part of our commitment to our membership we offer to refund and educate when members have issues with their accounts At that time the employee refunded half of the fees charged $on the account back to the member Multiple staff at Helena Community Credit Union have talked to this member about managing the account, using a check register to track spending, and the consequences of not tracking spending i.e Privilege Pay and the associated fees Staff advised her of ways to avoid fees, such as opting out of programs that may not be a good fit for her financially such as Privilege Pay They have explained how debit transactions post and clear through the account Using Privilege Pay, what should have been an insufficient was paid or approved rather than rejected or bounced Staff have analyzed and explained why fees were charged and then refunded fees as a courtesy It is unfortunate that this member feels singled out by the credit union Without analyzing every transaction on the members account to see if the member’s spending habits have changed during recent months, it appears that something has happened which is causing the system to access the Privilege Pay product to clear transactions We have a number of employees that specialize in guiding members toward financial success through the use of budgeting tools if she is interested If you would need additional information from Helena Community Credit Union, please contact me at 406-495- Sincerely, Lori [redacted] -M [redacted] VP Of Lending

April 17, 2017   Attn:  [redacted]                                     Response to complaint from [redacted] and...

[redacted] - Acct. [redacted]   Dear Mr. [redacted];   In researching [redacted]’s claim we have found all fees charged to her account were in compliance with our Privilege Payment (ODP or Courtesy Pay) program policies which are compliant with both state and federal regulations.  Additionally we have gone to great lengths to help [redacted] understand how this program works in order for her to avoid such fees in the future.  The credit union has reversed $636 in Privilege Pay fees since January of 2013 as an accommodation to assist her financially while providing valuable education about how our ODP program is to be used.  Our goal is to facilitate financial independence for [redacted] and the appropriate use of our products and services.            Ms. [redacted]’s complaint, as we understand, is that she is assessed fees based on her perception of what her account balance is.  In reviewing the account transactions, the member uses the debit card for most purchases. When the member is looking at the account balance online there are two balances showing, the ‘ledger balance’ and the ‘available balance’ which is confusing.  The available balance is the ledger balance less funds being held for items purchased with the debit card but not settled for payment.  The member has the ability in online banking to see what transactions are holding funds against the ledger balance.   When a member uses their debit card they can choose to process the transaction as PIN based purchase or as a signature based purchase.  If the member chooses a PIN based transaction, the transaction amount is immediately withdrawn from the account in real time.  If the member chooses a signature based transaction, the merchant requests an authorization for approval which places a hold for the transaction amount against the account balance thus reducing the available balance.  A hold can last up to 5 business days but will expire when the matching transaction posts.   The transaction doesn’t post to the member’s account until settlement occurs.  The settlement of the transaction is controlled by the merchant and when they batch their transactions.  Batching usually happens within two or three business days of the purchase, but per regulation the merchant has up to 6 months to present the transaction for payment.  If the member is using the online “ledger balance” to determine how much [redacted] they have, it will not show any uncleared (or unpresented) checks written or the amounts authorized and held for payment to the merchant.  When a member is relying on the online balances versus keeping a check register of their spending, they may overdraw their account.  Even though the amounts haven’t physically cleared the account the funds have already been spent.     All member accounts in good standing are qualified for “Privilege Pay” which allows them to overdraw the account up to $700.  If the member overspends what they have available, Privilege Pay will overdraw the account and pay the item saving the member the embarrassment of having items returned NSF.   Members can choose to not have access to Privilege Pay by opting out of the program.  If a member does not have Privilege Pay, debit items that would overdraw the account are not authorized and insufficient checks written are returned as NSF with a fee.  However, when Privilege Pay is accessed to pay amounts greater than the available balance in the account, a fee is assessed.    On 11/2/2016 the member spoke with an employee in our call center about her overdrawn account and the fees assessed on checks written.  The employee explained that the member had three pending debit transactions that were holding the funds and there weren’t monies available to clear the items without using the Privilege Pay program.    While the members have had access to privilege pay for a number of years, they did not Opt In for the Reg E portion of Privilege Pay until November 2016.  Prior to 11/15/2016 the member was unable to overdraw her account using a debit card because purchases without available funds could not be authorized at the merchant level.   On 11/15/16 the member contacted the credit union because a debit transaction she was trying to process was being denied.  At that time the member requested to be opted-in for Reg E so that the transaction would be approved.  The member has not revoked that opt in.  When debit transactions clear the account there may be a Privilege Pay fee charged if other transactions debit the account while the card authorization is holding funds against the available balance.   In addition to Privilege Pay, the credit union has a my!points program that rewards members for loyalty.   Points are rewarded for loan interest paid, dividends earned and debit card usage.  Points can be redeemed to refund a portion of fees assessed, lower interest rates on loans and increase certificate rates.   The credit union policy only allows two fee refunds per month.  In reviewing the notes on the member’s account, the credit union has refunded fees on a number of occasions using the my!points program and when she didn’t have points available exceptions were made.  In December 2013, the member was having similar issues with fees on the account.  She met with one of our member service staff who explained how the Privilege Pay program worked. As part of our commitment to our membership we offer to refund and educate when members have issues with their accounts.  At that time the employee refunded half of the fees charged $66.00 on the account back to the member.   Multiple staff at Helena Community Credit Union have talked to this member about managing the account, using a check register to track spending, and the consequences of not tracking spending i.e.  Privilege Pay and the associated fees.   Staff advised her of ways to avoid fees, such as opting out of programs that may not be a good fit for her financially such as Privilege Pay.  They have explained how debit transactions post and clear through the account.  Using Privilege Pay, what should have been an insufficient was paid or approved rather than rejected or bounced.  Staff have analyzed and explained why fees were charged and then refunded fees as a courtesy.    It is unfortunate that this member feels singled out by the credit union.  Without analyzing every transaction on the members account to see if the member’s spending habits have changed during recent months, it appears that something has happened which is causing the system to access the Privilege Pay product to clear transactions.  We have a number of employees that specialize in guiding members toward financial success through the use of budgeting tools if she is interested.   If you would need additional information from Helena Community Credit Union, please contact me at 406-495-6045.   Sincerely, Lori [redacted]-M[redacted]                                         ...⇄ VP Of Lending