A checking account at Woodforest Bank generated an average of $94 in overdraft fees during 2025, more than three times the $30 average at Regions Bank, the highest figure among the nation’s largest banks, according to a new tally of federal bank-filing data from the National Consumer Law Center. Both banks report to the same federal regulator on the same line item, so the gap between them is not an estimate pieced together from complaints — it comes from numbers the banks themselves filed. For a household weighing where to keep a checking account, the difference works out to roughly $260 a year in fees that either get charged or don’t, before anyone even looks at interest rates or minimum-balance requirements.
Where Woodforest and Regions Sit in a Five-Bank Field
Woodforest’s $94 average sits at the top of a five-bank field. First Convenience Bank follows at $68 per account, then Arvest Bank at $45. Regions Bank’s $30 average is the highest of any large national bank in the comparison, and Navy Federal Credit Union sits just behind it at $28, using the most recent year the National Consumer Law Center could confirm for that institution, 2024.
The ranking comes from Federal Financial Institutions Examination Council call reports, the standardized filings every FDIC-insured bank submits listing fee revenue by category, compiled by the National Consumer Law Center in a brief the group published in July 2026. The five numbers describe the same reporting line at five different institutions, which is what makes the spread notable: Woodforest’s average is more than three times Regions’ and well over triple Navy Federal’s.
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One Federal Line Item, Two Different Meanings
The figures are averages spread across every checking account at each bank, not a fee charged to any single customer. A household that never overdrafts contributes nothing to Woodforest’s $94 figure, while a household that overdrafts repeatedly can pay several times that amount in a single year. The National Consumer Law Center’s own brief makes the point directly: because the average gets diluted by non-overdrafters, anyone who does trigger the fee is paying well above the bank-wide number.
The same call-report line technically covers both overdraft fees and non-sufficient-funds fees, charged when a transaction is declined rather than paid. The brief notes that none of the twenty banks in its ranking charges NSF fees on top of overdraft fees, so for Woodforest, Regions and the rest, the entire figure represents overdraft revenue rather than a blend of two different charges.
Navy Federal Credit Union’s presence at the bottom of the field is also a reminder that the comparison spans more than one kind of institution. It is a credit union restricted to military-connected members rather than a retail bank open to the general public, which places it in a different membership and regulatory category than Woodforest, Regions, First Convenience and Arvest even though all five report fee revenue on the identical FFIEC line.
A Federal Cap That Never Took Effect
The comparison lands against a specific policy backdrop. The Consumer Financial Protection Bureau finalized a rule in late 2024 that would have capped most overdraft fees at large banks at $5, a change the bureau projected would save households that regularly overdraft roughly $225 a year. The rule would have applied only to banks holding more than $10 billion in assets, giving those institutions a choice: cap the fee at $5, cap it at a cost-based amount the bank could document, or treat overdraft coverage as a loan subject to standard lending disclosures. Congress voted to reverse the rule in 2025, and it never took effect, which is why banks remain free to set overdraft pricing as they see fit and why a $94 average and a $30 average can exist side by side without either bank crossing a federal price limit.
The National Consumer Law Center frames its new brief explicitly around that reversal, tracking fee levels in the year after the rule died rather than the year it was finalized. The timing is what turns a routine fee comparison into a policy story: the spread between Woodforest and Regions is exactly the kind of pricing gap the canceled rule would have narrowed.
The Uneven Split Behind the Industry Total
The same National Consumer Law Center data set also adds up overdraft and NSF fee revenue across the banking industry as a whole, a total that runs into the billions and gets its own treatment elsewhere. What the per-bank numbers add on top of that total is a sense of how unevenly the money is distributed: the top twenty consumer banks alone brought in roughly four billion dollars in overdraft fee revenue in 2025, and a disproportionate share of it traces back to a handful of banks running high per-account averages rather than being spread evenly across the industry. The wider industry figure, covering every bank and credit union rather than just the top twenty, ran above twelve billion dollars the prior year, which puts the four-billion-dollar concentration among the largest filers in proportion.
The National Consumer Law Center’s July brief frames the practical takeaway plainly: the bank a household happens to use, far more than any industry-wide trend, decides whether a $94-a-year average is a live possibility for that household’s account or a number that never touches it at all.
The Paperwork Gap After an Overdraft Fee Hits
An overdraft fee is a single line on a statement, but what follows it is often the bigger problem: a negative balance that lingers, a collector calling about the shortfall, or a bank freezing an account outright. Few households have the actual bank-protection timelines or dispute steps on hand before that call comes, so a routine fee turns into an improvised scramble.
The Bank Account & Debt Protection Kit lays out the 2-month bank protection rule and the debt-validation steps, along with the frozen-account response and a protected-funds and dispute log.
See the 2-month bank protection rule and the frozen-account response steps in The Bank Account & Debt Protection Kit.
AI-assisted research and drafting; reviewed by an editor.
