TCF National Bank stood out among other financial institutions in its practices, consumer watchdog CFPB said. It "designed its application process to obscure the fees and make overdraft seem mandatory for new customers," the CFPB said. For existing customers, the bank used "deceitful language" in scripts it gave to its employees, such as asking customers if they "wanted their TCF card to continue to exist as it does today," instead of clearer questions about consent for allowing their accounts to go into overdraft, a spokesman for the CFPB said.

About 66% of all TCF checking account customers had opted in to giving overdraft abilities on their accounts as of mid-2014, triple the average rate of opt-in at other banks, according to the CFPB's complaint. What's more, the bank in 2010 also held opt-in celebrations, the CFPB said: one to celebrate 300,000 opt-ins and another one to celebrate 500,000, with senior executives attending both. TCF's chief executive at the time of the 2010 opt-in rule even named a personal boat "The Overdraft," the complaint added.

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