Reg DD - Disclosure of Account Balances
Answer by John Burnett, BOL Guru Guru Bio
Question:
I would like to confirm that the new Reg DD final rule on Disclosure of Account Balances only affects the balances that must be displayed through an automated system, but not the amount of funds that may be accessed through that automated system. For example, we will need to display an account's ledger balance, but customers may still withdraw funds in excess of that amount if they have a demand deposit loan or a secondarily attached account for overdraft purposes.
Answer:
You have stated correctly that the rule does not prevent you from allowing the customer to access those other funds, assuming you have the capability to display one balance and authorize transaction using an enhanced balance.
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