04/02/2007
Is the limit for Executive Officer/Director's overdraft protection $5000 total for all accounts owned? Would one Executive Officer/Director having a $5000 plan for each multiple accounts be a violation?
07/31/2006
We are having a problem getting our account processing vendor to make programming changes to allow us to separately identify fees for paying overdrafts and fees for returning items. We have always applied an "overdraft item fee" regardless of whether the item is paid or bounced. Our vendor tells us that we aren't required to make the change because we don't offer an overdraft protection plan. Where, specifically, in the regulation does it say we have to make this change?
06/26/2006
If we do not advertise payments on overdraft, do we still have to make changes on our statements to include fees for returned and paid items?
06/12/2006
We are a small community bank of less that $75M regulated by FDIC. We offer no Overdraft Protection other than the "sweep account" from another deposit account. What new Reg DD changes would affect our bank?
01/09/2006
Regulation O prohibits banks from paying overdrafts on a executive officer or director unless they have a preauthorized transfer agreement. What does Regulation say about overdrafts to employees? Is this a management decision as to paying or returning employee overdrafts? What is considered best practice? Also, if an employee overdrafts an account but he has overdraft protection (through a bounce protection program), when do we consider him overdrawn? Would it be before overdraft protection kicks in or if he shows a negative balance after overdraft protection?
10/03/2005
If there is a checking account with a sole owner, and the customer wants to tie an overdraft protection line to the account; would it be a problem to have a co-signer for the line who is not also listed on the checking account?
08/29/2005
We are currently working on an ODP Policy and Procedures. It was stated that an account should be charged off no later than 60 days. We do our charge offs monthly. Do we have to change our method or can we charge them off the last day of the month even if it passes 60 days?
08/01/2005
Some questions recently arose about our OD protection plans and how they affect certain accounts that we offer.1. Our senior age is 50. Should we raise that to 62 or do we need to charge them the same for club checking that includes OD protection that we do for our other club members? 2. How does Reg Z affect the OD repayment plan? We offer customers 3 or 6 months to repay us.
08/01/2005
Our bank does not have an overdraft protection program, however, we do, as a courtesy to our customers, make pay or return decisions on a case-by-case basis. We charge a fee for NSF items that are paid and a fee for NSF items that we return, however, the fee we charge for NSF paid items is $5 more than the fee for NSF returned items. Because we charge a larger fee for NSF paid items, is this fee considered a finance charge under Reg. Z?
07/18/2005
Is it required that we send notification of overdrafts that take place. We did make note of it on our quarterly statement that we would no longer doing this. Are we in compliance?