Getting the right amount of rewards for signing up for a credit card shouldn't be hard. And frankly, most consumers don't expect that they could be charged twice for the same slip-up. Or expect that someone at a bank would open a credit card in their name without their knowledge or consent.

But marketing games abound and junk fees can make the business world go round.

On Tuesday, the Consumer Financial Protection Bureau took Bank of America to task for a list of illegal actions that undermine customer trust. Some practices have already been stopped, according to the bank. The bank did not admit or deny wrongdoing.

Bank of America agreed to pay a total of $150 million in fines and reimburse customers $100 million.

“Bank of America wrongfully withheld credit card rewards, double-dipped on fees, and opened accounts without consent,” said CFPB Director Rohit Chopra in a statement.

Chopra also stated that the government agency plans to put an "end to these practices across the banking system."

Consumer advocates applauded the regulatory action.

“Bank of America is a repeat offender. Being a household name that has been punished before didn’t stop it from allegedly cheating customers out of tens of millions of dollars in fees and credit card rewards and opening up accounts without their authorization,” Mike Litt, U.S. PIRG’s Consumer Campaign Director said in a statement.

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In early 2022, the Consumer Financial Protection Bureau announced that it would take a hard look into hidden fees and anticompetitive, harmful financial practices.

Chopra said then that the agency was in the process of ending the banking industry's reliance on what he called "exploitative" sources of income. 

Specifically, the federal financial watchdog agency stated Tuesday that Bank of America had engaged in:

Double-dipping: The bank had a previous policy of charging a $35 fee once — and then repeatedly for the same transaction — when a customer didn't have enough money in the account to cover the bill. If the company or person who was owed the money tried to resubmit that charge — and the money still wasn't in the customer's account — the bank would charge another $35 fee. These fees are often known as "bounced check fees" or "non-sufficient or insufficient funds" fees.

A retailer will commonly “re-present” returned transactions — trying to receive payment — often multiple times after a payment is initially denied, according to the CFPB. This can involve a regular check or automated clearinghouse transaction.

"Bank of America would assess these repeat non-sufficient fund fees potentially as soon as the next day after the initial transaction," according to the CFPB.

"Over a period of multiple years, Bank of America generated substantial additional revenue by illegally charging multiple $35 fees," according to the CFPB's statement. The Office of the Comptroller of the Currency also found that the bank’s double-dipping on fees was illegal.

Bank of America's response: The bank stopped charging what's called an NSF fee for "non-sufficient or insufficient funds" in early 2022 and dropped the $35 fee entirely. The bank will be going back through its database of consumers and reimbursing consumers directly if they were charged twice or more for the same transaction from September 2018 through January 2022. If a consumer no longer has an account with the bank, the bank would use the last known address to send the reimbursement.

"We voluntarily reduced overdraft fees and eliminated all non-sufficient fund fees in the first half of 2022," according to a bank spokesperson. "As a result of these industry leading changes, revenue from these fees has dropped more than 90%."

Bank of America's overdraft fee was reduced from $35 to $10. The new overdraft fee policy began in June 2022.

Under the CFPB order, Bank of America is required to compensate consumers charged unlawful non-sufficient funds fees if they have not already been made whole by the bank earlier. The watchdog agency estimates that $80.4 million in consumer fees were involved as part of double-dipping practices.

Under the consent order, PIRG's Litt noted, Bank of America will have 90 days to submit a plan for identifying, notifying, and compensating consumers who experienced the double-dipping of fees. The plan requires establishing a method to determine the compensation amounts. 

Then, Bank of America will have 60 days to provide that notification and compensation after the plan is approved.

Bank of America is required to reimburse affected customers by direct deposit, whenever possible or by check when not possible by direct deposit.

Withholding rewards: "Bank of America illegally withheld promised credit card account bonuses, such as cash rewards or bonus points, to tens of thousands of consumers," the CFPB stated.

At various times from 2012 through February 2021, Bank of America advertised "sign-up" bonuses online. Sometimes, it was worth $200 in cash rewards; other times 50,000 in points which amounted to a $500 value.

Regulators charged that the ad made it appear that the bonus was available to all applicants. And some online advertisements, according to the consent order, did not expressly state that sign-up bonus offers were limited only to online applicants.

Consumers thought the rewards applied elsewhere and apparently weren't told upfront by bank employees that the bank would not give the same rewards to consumers who submitted in-person or over-the-phone applications. It was an online-only kind of a deal.

The CFPB order requires that Bank of America must disclose material limitations on any rewards cards bonuses and provide bonuses as advertised.

In addition, regulators pointed to "employee error" saying that in some cases Bank of America offered a sign-up bonus for a rewards card to certain consumers but then didn't provide the promised bonuses. As part of the order, Bank of America must reimburse consumers who have been harmed and verify any previously administered redress, plus pay a $30 million civil penalty involving this issue. The bank previously paid about $23 million to consumers who were denied rewards bonuses, according to the CFPB.  

Bank of America will have 45 days, PIRG's Litt noted, to determine whether other rewards card customers are eligible for compensation and whether impacted customers have received full compensation. 

Opening unauthorized accounts: A now disbanded sales-based incentive and evaluation program apparently contributed to the misuse of consumer information and creation of unauthorized accounts. The CFPB states that going back to at least 2012 some Bank of America employees illegally applied for and enrolled consumers in credit card accounts without consumers’ knowledge or authorization. "In those cases, Bank of America illegally used or obtained consumers’ credit reports, without their permission, to complete applications," the CFPB stated.

"Because of Bank of America’s actions, consumers were charged unjustified fees, suffered negative effects to their credit profiles, and had to spend time correcting errors," the CFPB stated.

The consent order noted that opening new credit card accounts without a consumer's consent went against the bank's policies and procedures and involved a "small percentage" of the bank's new accounts.

Bank of America will have 30 days to submit a comprehensive plan for identifying, notifying, and compensating consumers who had credit card accounts opened without their authorization. 

The plan, PIRG's Litt noted, requires Bank of America to determine compensation amounts, make requests to credit bureaus to delete the tradelines associated with affected accounts, and make offers to affected consumers to close unauthorized accounts. 

Bank of America will have one year to provide that compensation after the plan is approved.

Bank of America, "in the interest of compliance and resolution of the matter, and without admitting or denying any wrongdoing," agreed to the consent order, according to regulatory filings.

Contact personal finance columnist Susan Tompor: [email protected]. Follow her on Twitter @tompor.