Read it and weep-----------
http://www.federalreserve.gov/newsevents/press/bcreg/20091112a.htm

Something else to think about, at this time, we have a little time to consider.

When will the madness end?!?!?

Election time!!

How on earth is this going to work?

Real life example: If a one time debit card transaction takes several days to clear through the account and in the meantime, the customer has a check clear that wipes out the balance of the account. The customer HAD the money last week when the debit card transaction occured - but now, the account is empty & last week's transaction OD's them today?

Wouldn't a hold be placed on the txn amt waiting to clear?

Do you hold the preauthorized $75 from the gas station for an actual $10 gas purchase and then return check presented for insufficient funds that are presented in the meantime?? Sounds like unlawful dishonor potential to me.

WOW, I just posted an article from CNN in another thread about this:

http://money.cnn.com/2009/11/12/news/economy/overdraft_fees/index.htm?section=money_topstories

Same info, just in the media's tone that congress is working for the people & the bad banks will not be able to hurt you anymore.

Logistically, this seems like a nightmare to me, especially for us small community banks. I assume there will be some definitions as to what Fed considers to be an ODP program, similar to the TIS def's regarding ODP's?

Glad that I'm retiring. This will be someone else's headache.

Let's see, rule is effective in January, mandatory in July... I am guessing perhaps in October as the rate they are going...

It's not at our bank. We are very small, and don't have card purchases post in real time.

I also have a question about pay-at-the-pump. In our neck of the woods, the merchants only hold $1 until the the true amount comes through. So the customer spends all the money in between and then the debit card purchase comes through wiping out the account.

What then?

UGHGH. Senior management is going to blow a gasket on this one. I think it might officially put them over the edge.

What then?

You just can't charge them an overdraft fee.

It is going to force all banks into a real time environment and have the customer opt-in in order to charge them OD fees on these types of transactions in the future.

Will this be strictly for structured ODP programs? We don't have an ODP program, the branch managers make the decision on paper items & pos transactions are sorted by their tran code automatically.

No. Not just for "structured ODP programs". According to the Fed, you have a OD program if you pay ODs.

Georgia Golfer, your program is how ours works too. You won't be able to charge a fee unless they have opted-in for the debit card & ATM OD payments.

So, in a nutshell...Structured ODP or not, if a one-time debit or ATM comes through, we must pay (because we can't return). IF the customer has opted-in, we can charge. IF they have not opted-in, we cannot charge. If this is correct, why on earth would anyone want to opt-in?

If someone has read through the reg yet (or seen this part) would you be so kind to direct me to a section that might discuss the returned item fees (for paper items, if the customer doens't 'opt in')?

THanks!

The rule does not affect overdraft fees for other than ATM and single debit card transactions, except that you cannot require a customer to opt in to OD coverage for those card transactions in order to get OD coverage for non-card transactions.

Can anyone define a "one-time debit card txn" for me??? :crazy

POS type of transaction not the type of recurring debit card transaction say where the customer arranges to pay their phone bill automatically every month via debit card.

thanks!