On September 28, 2022, the Bureau issued an order against Regions Bank, a bank headquartered in Birmingham, Alabama with consolidated assets over $163 billion. Previously, in 2015, the Bureau ordered Regions to cease certain unlawful conduct related to its charging overdraft fees to resolve the Bureau’s findings that Regions: (1) violated the law when it failed to obtain consent for overdraft fees from customers with linked savings accounts; and (2) deceived customers by charging them overdraft fees in connection with repaying deposit advances despite the bank’s representations that it would not charge such fees. In this case, the Bureau found that, from August 2018 through July 2021, Regions charged overdraft fees on debit-card purchases and ATM withdrawals even though consumers had sufficient funds when they made the transaction ( “Authorized-Positive Overdraft Fees”). There is a delay between the time a customer made a purchase with a debit card and when Regions pays the merchant from the customer’s account for the purchase. When a customer had sufficient funds in their account to make a debit-card purchase, Regions authorized the transaction and indicated that it was “holding” those funds aside. And yet, until July 2021, when it came time for Regions to pay the merchant for the initial purchase, Regions charged an overdraft fee on that purchase if the account’s available funds were insufficient to cover the purchase at that time. Regions assessed these fees as a result of counter-intuitive, complex practices that it knew customers did not understand. The Bureau found that Regions acted unfairly and abusively in violation of the Consumer Financial Protection Act of 2010 when it charged these Authorized-Positive Overdraft Fees fees. The Bureau also found that Regions could have discontinued the fee years ago but chose to wait while it pursued changes that would generate new overdraft fees to make up for the lost revenue from the illegal fee. The order prohibits Regions from charging Authorized-Positive Overdraft Fees and requires it to refund at least $141 million in unlawful overdraft fees and pay a $50 million civil money penalty.