Vast majority of NSF fees have been eliminated, saving consumers nearly $2 billion annually
Some financial institutions are behind the trend, continuing to charge these fees
CFPB recently analyzed the non-sufficient fund (NSF) fee practices of a number of banks and credit unions.1 NSF fees are charges that some financial institutions impose when they decline to make a payment from a consumer’s account, like a check or electronic authorization, after determining the account lacks sufficient funds. NSF fees are distinct from overdraft fees, which financial institutions charge when they pay, rather than decline, a payment when the account lacks sufficient funds. CFPB’s analysis found that—
- Nearly two-thirds of banks with over $10 billion in assets have eliminated NSF fees.2
- Nearly three-fourths of the banks that earned the most in overdraft/NSF fee revenue in 2021, including 27 of the top 30 earners, have eliminated NSF fees.
- Among credit unions with over $10 billion in assets, 16 of 20 continue to charge NSF fees, including four of the five largest.
CFPB used this analysis to estimate the resulting reduction in NSF fee revenue over the past several years. In their call reports, banks over $1 billion in assets are required to report their combined overdraft/NSF fee revenue separately from other deposit account service charges.3 Based on CFPB’s prior work, CFPB estimates that NSF fee revenue alone has typically comprised approximately 19% of combined overdraft/NSF fee revenue.4 Based on CFPB’s analysis and applying this assumption, CFPB estimates—
- Among banks with over $10 billion in assets, 97% of NSF fee revenue has been eliminated.
- Among the 75 banks earning the most overdraft/NSF fee revenue in 2021, 95% of NSF fee revenue has been eliminated.
- CFPB estimates that, as a result of the elimination of NSF fees at these banks, consumers are saving almost $2 billion annually on a going forward basis.5
Generally, larger banks have been more likely to eliminate NSF fees. All banks with over $75 billion in assets and all but seven of the 63 banks with over $25 billion in assets have eliminated NSF fees. Table 1 below shows bank NSF fee practices summarized by asset size. This table is followed by Tables 2, 3, and 4, which show NSF fee practices of the individual 75 banks earning the most in overdraft/NSF fee revenue in 2021, of individual banks with over $10 billion in assets, and of individual credit unions with over $10 billion in assets, respectively. CFPB will continue to monitor NSF fee practices in the market.
Table 1: NSF fee practice of banks with over $10 billion in assets, grouped by asset size
Assets | Total number of banks | Number of banks no longer charging NSF fees | Number of banks continuing to charge NSF fees |
---|---|---|---|
Over $200B |
14 |
14 |
0 |
$100B-$200B |
8 |
8 |
0 |
$75B-$100B |
5 |
5 |
0 |
$50B-$75B |
10 |
8 |
2 |
$25B-$50B |
26 |
21 |
5 |
$20B-$25B |
10 |
2 |
8 |
$15B-$20B |
20 |
14 |
6 |
$10B-$15B |
32 |
9 |
23 |
Total |
125 |
81 |
44 |
Table 2: NSF fee practice of the top 75 reporters of overdraft/NSF fee revenue in 2021
# | Name | Above $10B in assets? | 2021 Overdraft/NSF Revenue (000s) | Charges NSF fees? |
---|---|---|---|---|
1 |
WELLS FARGO |
Y | $1,414,000 |
N |
2 |
JPMORGAN CHASE |
Y | 1,211,000 |
N |
3 |
BANK OF AMERICA |
Y | 1,135,000 |
N |
4 |
TD BANK |
Y | 476,559 |
N |
5 |
TRUIST |
Y | 415,000 |
N |
6 |
U.S. BANK |
Y | 338,364 |
N |
7 |
REGIONS |
Y | 300,000 |
N |
8 |
PNC |
Y | 268,820 |
N |
9 |
USAA |
Y | 197,213 |
N |
10 |
HUNTINGTON |
Y | 151,638 |
N |
11 |
CITIZENS |
Y | 147,522 |
N |
12 |
WOODFOREST |
N | 144,572 |
N |
13 |
KEYBANK |
Y | 116,323 |
N |
14 |
FIRST NATIONAL BANK TEXAS/FIRST CONVENIENCE BANK |
N | 107,527 |
Y |
15 |
FIFTH THIRD |
Y | 107,473 |
N |
16 |
M&T BANK |
Y | 105,124 |
N |
17 |
CITIBANK |
Y | 101,000 |
N |
18 |
CAPITAL ONE |
Y | 73,380 |
N |
19 |
ARVEST BANK |
Y | 72,678 |
N |
20 |
BMO HARRIS |
Y | 63,983 |
N |
21 |
SANTANDER |
Y | 49,445 |
N |
22 |
FIRST-CITIZENS |
Y | 44,219 |
N |
23 |
FIRST HORIZON BANK |
Y | 41,109 |
N |
24 |
SOUTHSTATE BANK |
Y | 31,301 |
N |
25 |
HANCOCK WHITNEY BANK |
Y | 28,644 |
N |
26 |
CADENCE BANK |
Y | 28,268 |
N |
27 |
FROST BANK |
Y | 26,723 |
N |
28 |
FIRST NATIONAL BANK OF PENNSYLVANIA |
Y | 26,506 |
Y |
29 |
INTERNATIONAL BANK OF COMMERCE |
N | 26,077 |
Y |
30 |
ZIONS |
Y | 25,203 |
N |
31 |
ACADEMY BANK |
N | 23,616 |
Y |
32 |
COMMERCE BANK |
Y | 22,272 |
N |
33 |
GATE CITY BANK |
N | 21,928 |
N |
34 |
BOKF |
Y | 21,510 |
N |
35 |
BANCFIRST |
Y | 21,379 |
Y |
36 |
FIRSTBANK |
Y | 21,139 |
Y |
37 |
SIMMONS BANK |
Y | 21,081 |
Y |
38 |
GLACIER BANK |
Y | 20,753 |
N |
39 |
SYNOVUS BANK |
Y | 20,701 |
N |
40 |
THE CENTRAL TRUST BANK |
Y | 20,093 |
Y |
41 |
ASSOCIATED BANK |
Y | 19,575 |
N |
42 |
PROSPERITY BANK |
Y | 19,317 |
Y |
43 |
CITY NATIONAL BANK OF WEST VIRGINIA |
N | 19,309 |
Y |
44 |
BANKPLUS |
N | 19,052 |
Y |
45 |
BANCO POPULAR DE PUERTO RICO |
Y | 19,000 |
N |
46 |
OLD NATIONAL BANK |
Y | 18,967 |
N |
47 |
TRUSTMARK |
Y | 18,050 |
N |
48 |
MUFG UNION BANK * |
Y | 17,655 |
N |
49 |
COMMUNITY BANK |
Y | 17,632 |
N |
50 |
UMPQUA BANK |
Y | 16,168 |
N |
51 |
FIRST INTERSTATE BANK |
Y | 15,479 |
N |
52 |
RENASANT BANK |
Y | 15,078 |
N |
53 |
COMERICA BANK |
Y | 15,000 |
N |
54 |
WEBSTER BANK |
Y | 14,770 |
N |
55 |
FIRST FINANCIAL BANK |
Y | 14,561 |
N |
56 |
NORTHWEST BANK |
Y | 13,927 |
Y |
57 |
ATLANTIC UNION BANK |
Y | 13,752 |
N |
58 |
ARMED FORCES BANK |
N | 13,467 |
Y |
59 |
FLAGSTAR BANK |
Y | 13,052 |
N |
60 |
FULTON BANK |
Y | 12,844 |
N |
61 |
BANK OZK |
Y | 12,602 |
Y |
62 |
FIRST UNITED BANK AND TRUST COMPANY |
Y | 11,785 |
N |
63 |
AMERIS BANK |
Y | 11,389 |
N |
64 |
BANK OF HAWAII |
Y | 11,212 |
Y |
65 |
FIRST HAWAIIAN BANK |
Y | 11,187 |
Y |
66 |
MIDFIRST BANK |
Y | 10,568 |
N |
67 |
UNITED BANK |
Y | 10,308 |
N |
68 |
ROCKLAND TRUST COMPANY |
Y | 10,017 |
N |
69 |
FIRST COMMUNITY BANK |
N | 9,742 |
Y |
70 |
CAPITAL CITY BANK |
N | 9,159 |
Y |
71 |
NBT BANK |
Y | 9,071 |
Y |
72 |
COMMUNITY TRUST BANK |
N | 9,042 |
Y |
73 |
PATHWARD |
N | 8,813 |
N |
74 |
AMERICAN SAVINGS BANK |
N | 8,641 |
Y |
75 |
EASTERN BANK |
Y | 8,302 |
N |
*MUFG Union Bank was acquired by U.S. Bank in December 2022, and its deposit accounts transitioned to U.S. Bank in May 2023. According to U.S. Bank’s publicly available information, it has eliminated NSF fees including on accounts transitioned from MUFG Union Bank.
Table 3: NSF fee practice of banks with over $10 billion in assets
# | Bank Name | Assets as of March 31, 2023 (000s) | 2021 Overdraft/NSF Revenue (000s) | Charges NSF fees? |
---|---|---|---|---|
1 |
JPMORGAN CHASE |
$3,267,963,000 |
$1,211,000 |
N |
2 |
BANK OF AMERICA |
2,518,290,000 |
1,135,000 |
N |
3 |
CITIBANK |
1,721,547,000 |
101,000 |
N |
4 |
WELLS FARGO |
1,687,507,000 |
1,414,000 |
N |
5 |
U.S. BANK |
590,460,458 |
338,364 |
N |
6 |
TRUIST |
564,837,000 |
415,000 |
N |
7 |
PNC |
556,314,067 |
268,820 |
N |
8 |
CAPITAL ONE |
469,431,665 |
73,380 |
N |
9 |
TD BANK |
401,244,710 |
476,559 |
N |
10 |
BMO HARRIS |
265,445,972 |
63,983 |
N |
11 |
CITIZENS |
221,955,033 |
147,522 |
N |
12 |
FIRST-CITIZENS |
214,598,538 |
44,219 |
N |
13 |
FIFTH THIRD |
207,586,000 |
107,473 |
N |
14 |
M&T BANK |
202,362,791 |
105,124 |
N |
15 |
KEYBANK |
195,190,692 |
116,323 |
N |
16 |
HUNTINGTON |
188,441,474 |
151,638 |
N |
17 |
ALLY BANK |
186,383,000 |
3,000 |
N |
18 |
HSBC BANK USA |
164,491,861 |
3,272 |
N |
19 |
REGIONS |
153,125,000 |
300,000 |
N |
20 |
FLAGSTAR BANK |
123,633,012 |
13,052 |
N |
21 |
USAA |
110,977,000 |
197,213 |
N |
22 |
SANTANDER |
105,313,880 |
49,445 |
N |
23 |
MUFG UNION BANK* |
99,963,823 |
17,655 |
N |
24 |
CITY NATIONAL BANK |
96,370,058 |
1,138 |
N |
25 |
COMERICA BANK |
91,259,000 |
15,000 |
N |
26 |
ZIONS |
88,573,533 |
25,203 |
N |
27 |
FIRST HORIZON BANK |
80,465,472 |
41,109 |
N |
28 |
WEBSTER BANK |
74,793,203 |
14,770 |
N |
29 |
WESTERN ALLIANCE BANK |
70,985,869 |
569 |
Y |
30 |
EAST WEST BANK |
67,218,944 |
867 |
Y |
31 |
VALLEY NATIONAL BANK |
64,314,291 |
1,086 |
N |
32 |
SYNOVUS BANK |
61,725,582 |
20,701 |
N |
33 |
BANCO POPULAR DE PUERTO RICO |
55,618,000 |
19,000 |
N |
34 |
UMPQUA BANK |
53,985,895 |
16,168 |
N |
35 |
CIBC BANK USA |
52,145,757 |
- |
N |
36 |
CADENCE BANK |
51,693,096 |
28,268 |
N |
37 |
FROST BANK |
51,285,722 |
26,723 |
N |
38 |
OLD NATIONAL BANK |
47,554,040 |
18,967 |
N |
39 |
BOKF |
45,269,054 |
21,510 |
N |
40 |
PINNACLE BANK |
44,987,683 |
4,532 |
N |
41 |
SOUTHSTATE BANK |
44,902,537 |
31,301 |
N |
42 |
FIRST NATIONAL BANK OF PENNSYLVANIA |
44,131,723 |
26,506 |
Y |
43 |
ASSOCIATED BANK |
40,652,795 |
19,575 |
N |
44 |
UMB BANK |
40,354,002 |
4,385 |
N |
45 |
PROSPERITY BANK |
37,828,891 |
19,317 |
Y |
46 |
HANCOCK WHITNEY BANK |
37,524,865 |
28,644 |
N |
47 |
MIDFIRST BANK |
37,240,719 |
10,568 |
N |
48 |
BANKUNITED |
37,095,206 |
340 |
N |
49 |
TIAA |
36,801,333 |
240 |
N |
50 |
COMMERCE BANK |
31,853,365 |
22,272 |
N |
51 |
FIRST INTERSTATE BANK |
31,565,171 |
15,479 |
N |
52 |
UNITED BANK |
30,108,080 |
10,308 |
N |
53 |
BANK OZK |
28,971,170 |
12,602 |
Y |
54 |
FIRSTBANK |
28,763,618 |
21,139 |
Y |
55 |
TEXAS CAPITAL BANK |
28,591,507 |
53 |
N |
56 |
FIRST NATIONAL BANK OF OMAHA |
28,393,321 |
6,551 |
N |
57 |
GLACIER BANK |
27,784,636 |
20,753 |
N |
58 |
SIMMONS BANK |
27,538,237 |
21,081 |
Y |
59 |
FULTON BANK |
26,996,012 |
12,844 |
N |
60 |
ARVEST BANK |
26,945,886 |
72,678 |
N |
61 |
CITY NATIONAL BANK OF FLORIDA |
26,204,489 |
2,845 |
N |
62 |
AMERIS BANK |
25,991,033 |
11,389 |
N |
63 |
UNITED COMMUNITY BANK |
25,814,879 |
7,859 |
N |
64 |
FIRST HAWAIIAN BANK |
24,883,294 |
11,187 |
Y |
65 |
BANK OF HAWAII |
23,903,516 |
11,212 |
Y |
66 |
EASTERN BANK |
22,702,386 |
8,302 |
Y |
67 |
CENTENNIAL BANK |
22,451,769 |
5,088 |
Y |
68 |
WASHINGTON FEDERAL BANK |
22,319,547 |
3,343 |
Y |
69 |
CATHAY BANK |
22,015,796 |
157 |
Y |
70 |
CUSTOMERS BANK |
21,768,466 |
97 |
Y |
71 |
PACIFIC PREMIER BANK |
21,362,450 |
674 |
N |
72 |
BANK OF HOPE |
20,563,590 |
653 |
Y |
73 |
WILMINGTON SAVINGS FUND SOCIETY |
20,218,887 |
7,052 |
N |
74 |
ATLANTIC UNION BANK |
19,989,774 |
13,752 |
N |
75 |
ROCKLAND TRUST COMPANY |
19,445,034 |
10,017 |
N |
76 |
FIRSTBANK PUERTO RICO |
18,969,247 |
4,474 |
N |
77 |
AXOS BANK |
18,940,273 |
191 |
N |
78 |
TRUSTMARK NATIONAL BANK |
18,874,809 |
18,050 |
N |
79 |
THE CENTRAL TRUST BANK |
18,850,388 |
20,093 |
Y |
80 |
INDEPENDENT BANK/INDEPENDENT FINANCIAL |
18,793,142 |
2,952 |
Y |
81 |
FIRST MERCHANTS BANK |
18,164,976 |
3,177 |
N |
82 |
MECHANICS BANK |
17,946,221 |
6,908 |
Y |
83 |
RENASANT BANK |
17,479,420 |
15,078 |
N |
84 |
WESBANCO BANK |
17,236,685 |
3,349 |
Y |
85 |
APPLE BANK FOR SAVINGS |
16,888,361 |
229 |
N |
86 |
FIRST FINANCIAL BANK |
16,856,740 |
14,561 |
N |
87 |
TOWNEBANK |
16,730,476 |
715 |
N |
88 |
THIRD FEDERAL SAVINGS & LOAN ASSOCIATION OF CLEVELAND |
16,249,256 |
203 |
Y |
89 |
BREMER BANK |
15,763,213 |
2,362 |
N |
90 |
BANNER BANK |
15,525,483 |
2,061 |
N |
91 |
FIRST UNITED BANK AND TRUST COMPANY |
15,411,885 |
11,785 |
N |
92 |
SEACOAST NATIONAL BANK |
15,247,533 |
2,204 |
Y |
93 |
COMMUNITY BANK |
15,032,060 |
17,632 |
N |
94 |
SERVISFIRST BANK |
14,565,304 |
225 |
N |
95 |
NORTHWEST BANK |
14,270,252 |
13,927 |
Y |
96 |
SANDY SPRING BANK |
14,126,844 |
1,664 |
N |
97 |
PLAINSCAPITAL BANK |
13,836,907 |
1,619 |
Y |
98 |
DIME COMMUNITY BANK |
13,826,566 |
525 |
Y |
99 |
PROVIDENT BANK |
13,773,422 |
4,246 |
N |
100 |
FIRST FOUNDATION BANK |
13,585,967 |
300 |
Y |
101 |
OCEANFIRST BANK |
13,447,967 |
3,207 |
Y |
102 |
ENTERPRISE BANK & TRUST |
13,300,684 |
1,363 |
Y |
103 |
SOFI BANK |
13,239,321 |
- |
N |
104 |
BELL BANK |
13,134,999 |
2,543 |
Y |
105 |
FIRSTBANK |
13,092,730 |
5,044 |
N |
106 |
FIRST FINANCIAL BANK |
12,952,033 |
7,919 |
Y |
107 |
VERITEX COMMUNITY BANK |
12,601,304 |
270 |
Y |
108 |
FIRST BANK |
12,367,423 |
6,076 |
N |
109 |
BERKSHIRE BANK |
12,314,668 |
6,638 |
Y |
110 |
BUSEY BANK |
12,314,348 |
5,898 |
Y |
111 |
POPULAR BANK |
12,145,033 |
1,017 |
N |
112 |
FARMERS AND MERCHANTS BANK OF LONG BEACH |
12,021,615 |
498 |
Y |
113 |
NBT BANK |
11,758,898 |
9,071 |
Y |
114 |
DOLLAR BANK |
11,446,147 |
7,416 |
N |
115 |
FIRST COMMONWEALTH BANK |
11,084,845 |
7,831 |
Y |
116 |
EAGLEBANK |
11,040,406 |
62 |
Y |
117 |
LAKELAND BANK |
10,836,959 |
1,695 |
Y |
118 |
STELLAR BANK |
10,595,556 |
1,601 |
Y |
119 |
HTLF BANK |
10,512,717 |
2,408 |
Y |
120 |
WASHINGTON TRUST BANK |
10,505,374 |
1,485 |
Y |
121 |
BANCFIRST |
10,424,300 |
21,379 |
Y |
122 |
COLUMBIA BANK |
10,313,354 |
2,151 |
Y |
123 |
ORIGIN BANK |
10,301,973 |
1,755 |
Y |
124 |
CAPITOL FEDERAL SAVINGS BANK |
10,098,222 |
2,267 |
N |
125 |
BANC OF CALIFORNIA |
10,033,324 |
594 |
Y |
*MUFG Union Bank was acquired by U.S. Bank in December 2022, and its deposit accounts transitioned to U.S. Bank in May 2023. According to U.S. Bank’s publicly available information, it has eliminated NSF fees including on accounts transitioned from MUFG Union Bank.
Table 4: NSF fee practice of credit unions with over $10 billion in assets
# | Credit Union Name | Assets as of March 31, 2023 (in billions) | Charges NSF fees? |
---|---|---|---|
1 | NAVY FEDERAL CREDIT UNION | $166.0 | Y |
2 | STATE EMPLOYEES CREDIT UNION (NC) | 50.8 | Y |
3 | PENTAGON FEDERAL CREDIT UNION | 35.3 | Y |
4 | BOEING EMPLOYEES CREDIT UNION | 28.9 | N |
5 | SCOOOLSFIRST CREDIT UNION | 28.6 | Y |
6 | GOLDEN 1 CREDIT UNION | 19.6 | Y |
7 | ALLIANT CREDIT UNION | 19.0 | N |
8 | AMERICA FIRST FEDERAL CREDIT UNION | 18.3 | N |
9 | FIRST TECHNOLOGY FEDERAL CREDIT UNION | 17.0 | Y |
10 | MOUNTAIN AMERICA FEDERAL CREDIT UNION | 17.0 | Y |
11 | SUNCOAST CREDIT UNION | 16.9 | Y |
12 | RANDOLPH-BROOKS FEDERAL CREDIT UNION | 16.9 | Y |
13 | VYSTAR CREDIT UNION | 13.8 | Y |
14 | SECURITY SERVICE FEDERAL CREDIT UNION | 13.1 | Y |
15 | LAKE MICHIGAN CREDIT UNION | 12.4 | Y |
16 | BETHPAGE FEDERAL CREDIT UNION | 12.3 | Y |
17 | GLOBAL CREDIT UNION | 11.7 | N |
18 | SAN DIEGO COUNTY CREDIT UNION | 11.1 | Y |
19 | GREENSTATE CREDIT UNION | 11.1 | Y |
20 | STAR ONE CREDIT UNION | 10.3 | Y |
Endnotes
-
Between April 25 and August 29, 2023, CFPB reviewed publicly available information describing financial institutions’ NSF fee practices. Where a financial institution had announced planned elimination of NSF fees, this spotlight categorizes that institution as not charging NSF fees. Any unannounced changes or any changes a financial institution may have announced or disclosed subsequent to CFPB’s review of that financial institution’s practice will not be reflected herein. CFPB did not independently verify financial institutions’ practices, and the inclusion of individual institutions named within this issue spotlight does not reflect a CFPB endorsement of a financial institution.
↩ -
Asset sizes throughout this analysis are according to Call Report data as of March 31, 2023. The analysis in this spotlight of banks with over $10 billion in assets generally excludes banks without mass market checking accounts.
↩ -
All reported combined overdraft/NSF fee revenue herein is derived from banks’ Consolidated Reports of Condition and Income (Call Reports) submitted to the Federal Financial Institutions Examinations Council. This analysis excludes NSF revenue collected by banks with assets of less than $1 billion and by all credit unions, as those institutions are not required to publicly report their overdraft/NSF fee revenue as a separate line item.
↩ -
See CFPB Data Point: Checking account overdraft at 10, Table 2 (July 2014), available at https://files.consumerfinance.gov/f/201407_cfpb_report_data-point_overdrafts.pdf . CFPB applies this assumption throughout this analysis.
↩ -
Total overdraft/NSF fee revenue in 2019 reported by banks with over $1 billion in assets was $11.97 billion. CFPB analyzed the NSF fee practices of banks with over $10 billion in assets as of March 31, 2023, and the 75 banks earning the most in overdraft/NSF fee revenue in 2021 (some of which are under $10 billion in assets). For each of these banks, CFPB generally estimated NSF revenue by applying 18.9% to the reported overdraft/NSF revenue in 2021 (except in the rare case the bank does not have a known overdraft program, in which case all overdraft/NSF revenue for the bank was considered NSF revenue). The estimated NSF revenue of banks that no longer charge NSF fees accounts for 86% of the total estimated NSF revenue in 2021 of all banks over $1 billion in assets. Thus, CFPB estimates that at least 86% of ongoing reported NSF revenue has been eliminated. CFPB then applies that 86% to the overdraft/NSF revenue for banks over $1 billion in assets reported in 2019, a pre-pandemic baseline of overdraft/NSF revenue that CFPB has used in other reports and a comparable market to today. That math is as follows: $11.97B (2019 total overdraft/NSF revenue for banks over $1 billion), multiplied by the 18.9% portion that CFPB estimates is NSF fee revenue, multiplied by 86% eliminated, results in an estimated $1.94 billion in NSF fees eliminated going forward.
↩