POS most certainly counts as a debit card transaction. In fact, it's the lag-time built into signature authorized POS transactions that has the regulators so exercised on the question. Holds aren't attacked in the proposals, though. What is attacked is the assessment of overdraft fees triggered exclusively by a hold when the hold is greater than the final transaction (if the actual transaction would not have triggered the fee on its own).
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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