According to the final Reg DD rule effective next year, we cannot include the overdraft balance on a balance inquiry at ATM, phone, Internet etc unless we provide information describing the balance as including an overdraft plan. Our bank doesn't currently provide the overdraft amount on balance inquiries, however, it does provide two separate balances after an ATM withdrawal, with one balance including the overdraft funds. The reg only refers to balance inquiries, but would we need to inform the customer on an ATM withdrawal or transfer that o/d funds are included in that balance?
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CRCM CAMs