THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF IOWA
Jones v. Bankers Trust Company, No. 4:23-cv-00477
If you were assessed a Challenged Fee1 by Bankers Trust
Company, you could get a payment and/or other benefits
from a class action settlement.
A court authorized this notice. This is not a solicitation from a lawyer.
• The settlement relates to certain fees (defined in footnote 1 below as “Challenged Fees”) that
Bankers Trust Company (“Defendant”) charged. If you were charged such a fee, you are a member
of the Settlement Class (each, a “Class Member”).
• Class Members who do nothing will automatically receive a check or account credit and/or debt
forgiveness. Payments and credits will be from the Net Settlement Fund based on a percentage of
the amount of applicable fees paid. The amount of these payments will be determined by an
independent settlement administrator and not by Defendant.
• Your legal rights are affected, so please read this notice carefully.
YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT:
DO NOTHING Automatically receive a settlement check or account credit and/or
debt forgiveness once the settlement is finally approved. Give up
the right to bring a separate lawsuit about the same issues.
EXCLUDE Get no benefits from the settlement. Keep the right to bring a separate
YOURSELF lawsuit about the same issues at your own expense.
Write to the Court about why you don’t like the settlement. If the
settlement is approved you will still automatically receive a check or
OBJECT
account credit and/or debt forgiveness and give up the right to bring a
separate lawsuit about the same issue.
1
“Challenged Fees” means: (1) Overdraft fees incurred during the Class Period on debit card
transactions authorized on a sufficient available balance (“APSN Fees”); and
(2) Overdraft fees incurred during the Class Period for one-time debit card transactions and ATM
transactions (“Reg-E Fees”). The “Class Period” is for APSN Fees, December 1, 2016, through April 3,
2023; and, for Reg-E Fees, December 1, 2022, through April 3, 2023. Capitalized terms used and not
otherwise defined herein are defined in the Settlement Agreement.
Questions? Call 844-496-1128 or visit www.BTSettlement.com Page
1757807059.1
• These rights and options—and the deadlines to exercise them—are explained in this notice.
• Please be patient while the Court decides whether to approve the settlement.
BASIC INFORMATION
1. Why did I get this notice?
If you received a postcard notice or email relating to this case then the records of Defendant show that you
were assessed a Challenged Fee (as defined in footnote 1, above). Because of this, you are a Class
Member, and you may be affected by this class action settlement.
The Court is providing this notice because you have a right to know about the proposed class action
settlement, and about your options, before the Court decides whether to approve the settlement. If you do
nothing and the Court approves the settlement, and after any appeals are resolved, the benefits of the
settlement will be provided to you.
This package explains the lawsuit, the settlement, your legal rights, what benefits are available, and how
those benefits will be calculated.
The Court in charge of the case is The United States District Court for the Southern District of Iowa, and
the case is known as Jones v. Bankers Trust Company. The person who sued is called the Plaintiff, and the
entity sued is called the Defendant.
2. What is the lawsuit about?
The lawsuit claims that Defendant improperly assessed the Challenges Fees described in footnote 1
above. Defendant denies that it did anything wrong. Defendant claims that it was allowed to assess these
fees and properly did so in accordance with the terms of its account agreements and applicable law.
3. Why is this a class action?
In a class action lawsuit, one or more people called “Class Representatives” (in this case, Plaintiff
Stephanie Jones) sue on behalf of themselves and other people who have similar claims. All of these
people are called Class Members, and together they form the Settlement Class. This is a class action
because the Court has decided it meets the legal requirements to be a class action solely for the purposes
of settlement and notice. Because the case is a class action, one court resolves the issues for everyone in
the Settlement Class, except for those people who choose to exclude themselves from the Settlement
Class.
Questions? Call 844-496-1128 or visit www.BTSettlement.com Page
1757807059.1
4. Why is there a settlement?
The Court did not decide in favor of the Plaintiff or the Defendant. Instead, both sides agreed to a settlement.
That way, they avoid the cost of a trial and the risks of either side losing, and they ensure that the people
affected by the lawsuit receive compensation. Defendant does not in any way acknowledge, admit to or
concede any of the allegations in the lawsuit and expressly disclaims and denies any and all fault or liability
for the charges that have been alleged in this lawsuit. The parties think that the settlement is best for
everyone involved under the circumstances. Subject to it considering any objections, the Court has
determined the settlement is fair, reasonable, and adequate.
WHO IS IN THE SETTLEMENT
To see if you will be provided with benefits from this settlement, you first have to decide if you are a Class
Member.
5. How do I know if I am part of the settlement?
If you received an email or postcard notice addressed to you then you are a Class Member , you will be a
part of the settlement, and the applicable benefits of the settlement will be provided to you, unless you
exclude yourself. If you are not sure whether you have been properly included, you can call the number at
the bottom of this notice to check.
THE SETTLEMENT BENEFITS—WHAT YOU GET
6. What does the settlement provide?
The Defendant has agreed to pay $550,000 into a Settlement Fund to settle this case, plus Defendant will
forgive and charge-off all uncollected overdraft fees from the Class Period on Class Member accounts
(“Debt Forgiveness”), making the total Value of the Settlement no less than $564,283.26. As discussed
separately below, attorneys’ fees, Class Counsel’s expenses, the costs of this notice and the costs of
distributing the settlement benefits, among other settlement administration costs, and the Service Award
Amount to the Class Representative will also be paid out of the Settlement Fund.
7. What can I get from the settlement?
After deducting the attorneys’ fees and expenses, costs of notice and administration, and Service Award
Amount to the Class Representative approved by the Court, there will be a Net Settlement Fund available
for distribution to Class Members who do not exclude themselves from the Settlement Agreement. Each
such Class Member will be paid from this fund on a pro rata basis, based on the amount of applicable
Challenged Fees paid by the Class Member. For example, a Class Member who paid $1,000 in applicable
fees will receive a check or account credit for twice as much as a Class Member who paid $500 in
applicable fees.
Questions? Call 844-496-1128 or visit www.BTSettlement.com Page
1757807059.1
The actual amount of any Class Member’s check or account credit will be determined by an independent
settlement administrator based on the following formula:
Total Amount of Challenged
Fees Paid by Class Member
During the Class Period
Class Member's Distribution = × Net Settlement Fund
Total Amount of Challenged
Fees Paid by All Class
Members During the Class
( Period )
You will not receive more in the settlement than the amount of the applicable fees that you paid during the
Class Period and are likely to receive less.
If there are uncollected funds after the first distribution, there will be subsequent distributions in the same
manner as the first to the persons who successfully received an account credit or cashed their check in
the prior distribution round. Once Class Counsel determines that it would not be feasible to make further
distributions to Class Members based on the administrative costs of the distribution, which will be paid
from the Settlement Fund, any remaining uncollected funds will be paid on a cy pres basis to a charity
approved by the Court. The parties are recommending that the Court make an award to Habitat for
Humanity. If you think another charity would better serve the interests of the Settlement Class, you may
write to the Settlement Administrator at the address in Question 11 to recommend a different charity and
to explain why you believe the charity is appropriate. The Settlement Administrator will pass your
recommendation onto Class Counsel who will file it with the Court.
8. What do I need to do to receive a payment from the settlement?
You do not need to do anything to receive a payment from the settlement or account credit and/or debt
forgiveness. As long as you do not exclude yourself, you will receive a settlement check or account credit
and/or debt forgiveness if the settlement becomes final and if you are eligible. If your address changes,
however, please call the number at the bottom of this notice to report the address change so that your
payment reaches you.
9. When would I get my payment?
Once the settlement is finally approved, a judgment is entered, and any appeals of the Court’s approval of
the settlement are resolved or if no appeals are filed, it will be possible to distribute the funds. This may
take several months and perhaps more than a year. You do not need to do anything to receive your
payment.
10. What am I giving up to get a payment?
Unless you exclude yourself, you are staying in the Settlement Class, and that means you can’t sue,
continue to sue, or be part of any other lawsuit against Defendant and any other Released Parties relating
to the legal claims that were or could have been brought in this case (the “Released Claims,” as defined in
Questions? Call 844-496-1128 or visit www.BTSettlement.com Page
1757807059.1
the Settlement Agreement). It also means that all of the Court’s orders will apply to you. Once the
settlement is final, any Released Claims that you may have will be released and forever barred.
EXCLUDING YOURSELF FROM THE SETTLEMENT
If you don’t want a payment, account credit, or any other benefits from this settlement, but you want to
keep the right to sue or continue to sue the Defendant on your own about the legal issues in this case, then
you must take steps to get out. This is called excluding yourself—or is sometimes referred to as opting out
of the Settlement Class.
11. How do I get out of the settlement?
To exclude yourself from this settlement, you must send a letter by mail saying that you want to opt-out or
be excluded from Jones v. Bankers Trust Company. The letter must include your name, address, telephone
number, and your signature. You must mail your exclusion request postmarked no later than April 27,
2026 to:
Jones v. Bankers Trust Company Exclusions
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
You can’t exclude yourself on the phone or by e-mail or by letter to a different address. If you ask to be
excluded, you will not get any settlement payment or credit and you cannot object to the settlement. You
will not be legally bound by anything that happens in this lawsuit. You may be able to sue (or continue to
sue) the Defendant in the future.
12. If I don’t exclude myself, can I sue later for the same thing?
No. Unless you exclude yourself, you give up the right to sue the Defendant or any other Released Parties
for the Released Claims that this settlement resolves. If you have a pending lawsuit, speak to your lawyer
in that suit immediately. You must exclude yourself from this Class to continue your own lawsuit.
Remember that the exclusion deadline is April 27, 2026. You can review the scope of the releases of your
right to sue Defendant and others in paragraph 4 of the Settlement Agreement.
13. If I exclude myself, can I get money from this settlement?
No. If you exclude yourself, you are not eligible for any money or benefits from this settlement.
THE LAWYERS REPRESENTING YOU
14. Do I have a lawyer in this case?
The Court appointed the law firms of CohenMalad, LLP; Gibbs Law Group LLP; Roxanne Conlin &
Associates, O.C.; and Stranch, Jennings & Garvey, PLLC to represent you and other Class Members.
Questions? Call 844-496-1128 or visit www.BTSettlement.com Page
1757807059.1
Together, the lawyers are called Class Counsel. You will not be charged for these lawyers. If you want to be
represented by your own lawyer, you may hire one at your own expense.
15. How will the lawyers be paid?
The Court will enter a final judgment for attorneys’ fees for the amount of $188,094.42 to be paid from the
Settlement Fund, plus reimbursement of Class Counsel’s expenses of $13,236.74, and a service award to
the Class Representative of $5,000, to be paid from the Settlement Fund.
OBJECTING TO THE SETTLEMENT
You can tell the Court that you don’t agree with the settlement or some part of it.
16. How do I tell the Court that I don’t like the settlement?
If you’re a Class Member, you can object to the settlement if you don’t like any part of it. You must state the
reasons for your objection and include any evidence, briefs, motions or other materials you intend to offer
in support of the objection. The Court may consider your views. To object, you must send a letter saying
that you object to Jones v. Bankers Trust Company. You must include your name, address, telephone
number, your signature, and the reasons you object to the settlement, along with any evidence or legal
argument that supports your objection. You must mail the objection to the following address postmarked
no later than April 27, 2026:
Jones v. Bankers Trust Company Objections
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
17. What’s the difference between objecting and excluding?
Objecting is simply telling the Court that you don’t like something about the settlement. You can object
only if you stay in the Settlement Class. Excluding yourself is telling the Court that you don’t want to be part
of the Settlement Class. If you exclude yourself, you have no basis to object because this case no longer
affects you.
IF YOU DO NOTHING
18. What happens if I do nothing at all?
If you do nothing, you will be a part of this settlement, and you will be provided the payments or account
credit and any other benefits provided by the settlement once it becomes final. In exchange for the
payment or credit and/or debt forgiveness you won’t be able to start a lawsuit, continue with a lawsuit, or
be part of any other lawsuit against the Defendant relating to the claims released in the Settlement
Agreement.
Questions? Call 844-496-1128 or visit www.BTSettlement.com Page
1757807059.1
GETTING MORE INFORMATION
19. Are there more details about the settlement?
This Notice summarizes the proposed Settlement. More details are in the Settlement Agreement. You
can get a copy of the Settlement Agreement on the Settlement website, www.BTSettlement.com. You
can call the Settlement Administrator at (866) 675-2696. Before doing so, however, please read the full
Notice carefully.
Questions? Call 844-496-1128 or visit www.BTSettlement.com Page
1757807059.1
