
Since at least 2001 for consumer banking customers and since 2002 for business banking customers, PNC represented in marketing and account disclosures that it would waive annual, origination, and/or overdraft protection transfer fees (collectively, “Fees”) charged to certain line of credit (“LOC”) accounts for consumer and business banking customers with qualifying demand deposit accounts (hereinafter referred to as “qualified consumer banking customers” and “qualified business banking customers”). (2) In 2016, PNC Executive Management found that PNC failed to waive the Fees since at least 2001 for some qualified consumer banking customers and since at least 2002 for some qualified business banking customers, and reported its findings to the OCC and PNC’s Board of Directors