We recently purchased a bank and they are wanting to have overdraft shelter. They currently charge a $7 daily fee for each day you are overdrawn. Can they do this without giving out Reg Z disclosures? It has been a long time since we set up our Overdraft Shelter and I remember that we used to charge a % fee for overdrafts and we had to stop doing that so that we wouldn't have to treat it like a loan. This overdraft shelter is not attached in any form to a loan. Please HELP!!