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Latest Compliance - Overdraft Protection Topics

Overdraft Transfers and ACH Transactions

09/16/2018

I have been setting up overdraft transfers for funds trying to pull from savings for ACH transactions. They have funds in their checking, and when I set it up and then repost occurs, the funds are transferred from checking along with a transfer fee. Do you know if I am breaking any rules? Normally I would be transferring funds manually. Or should we just be returning the items.

Overdrafts and UDAP

11/27/2016

Is UDAP (Unfair or Deceptive Acts or Practices) a concern with overdraft services?

Disclosing account balances

11/20/2016

May a financial institution disclose a single balance inclusive of overdraft protection funds (i.e. a line of credit or discretionary service amount)?

Maximizing overdraft income

11/13/2016

May a financial institution process transactions in a manner that allows the financial institution to maximize overdraft fee income?

Reg E overdraft opt-ins

04/24/2016

We do not approve overdrafts unless a customer has a line of credit or ties a savings account to the checking. Should we be obtaining an opt-in so we can charge a fee if the customer does not have available funds in the line of credit or savings account?

Advance On OD Line of Protection- Notice?

05/12/2014

When an advance is made on an overdraft line of protection is a notice (advance notice) required to be sent to the Borrower? If so, which regulation does this fall under?

Request OD Protection Again After Reg D Violation

04/01/2013

A customer's savings account is set up to protect his checking via overdraft protection and he has violated Reg D for three consecutive months and the bank has removed the overdraft capability, following all requirements of course. When can he or can he request overdraft protection from his savings to his checking again?

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UDAAP and Overdraft Protection

FDIC has issued warnings about the possibility of certain overdraft protection programs failing the UDAAP test. It has happened.

Gift Horses and Pigs in Pokes

There is a lot of wisdom-based guidance in maxims that have been used for centuries. "Don't look a gift horse in the mouth" is a popular one.

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Privacy among applicants

06/20/2021

If credit is denied because of issues related to only one applicant, for example a charge-off, can we disclose that reason to both applicants, and do both applicants get an Adverse Action Notice?

ATM fee notice

06/20/2021

This fee notice is no longer required to be posted on the machine if there is a screen that pops up before the fee is assessed.

Chipped Cards=Less Fraud

06/20/2021

Do you have any recommendations on investigating dispute claims where a chip card is used? Our processor says we have no chargeback rights and can't do anything when a chip reader has been used. Customers still claim the transactions are not theirs and we are stuck with no other option but to pay the claim.

Where to Send Counterfeit Currency

06/20/2021

Is a bank required to send in counterfeit currency to the Secret Service or report and turn it into the local police department?

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