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#1286355 - 11/13/09 07:38 PM Reg DD Revisions & Change-in-Terms Notice
Valley Girl Offline
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Joined: Feb 2008
Posts: 142
Bank currently displays two balances at the ATM. Due to the Reg. DD revisions; the bank will only display the actual balance. I don't think a change-in-terms notice would be required since the change doesn't adversely affect the customer and it is a regulatory requirement. Is that right?

Thanks!!

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#1286488 - 11/13/09 09:04 PM Re: Reg DD Revisions & Change-in-Terms Notice Valley Girl
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
There is no change in terms on the accounts involved. However, don't you think there is need to explain what's happening in general terms so that you won't be snowed under in January by customer complaints or questions?
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#1290009 - 11/19/09 09:28 PM Re: Reg DD Revisions & Change-in-Terms Notice John Burnett
Bobw Offline
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Bobw
Joined: Nov 2006
Posts: 336
New England
I understand the question was Change in terms, but as long as the ATM shows and identifies the acutual balance it can show both available and unavailable as long as it is id'd?
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just my opinion, based on my 30+ years

GO RED SOX!!!

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#1291505 - 11/23/09 05:13 PM Re: Reg DD Revisions & Change-in-Terms Notice Bobw
John Burnett Offline
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John Burnett
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Cape Cod
I'll avoid the terms "available" and "unavailable" because with ODP they can be confusing.

If you provide a balance at an ATM, on a voice response unit, on your online banking system, or via any other automated system that can provide a balance directly to your consumer depositor,

1. That balance cannot include any funds from any source other than the account in question (it can't be "enhanced" with an amount that the bank would allow the account be be paid into overdraft, by an amount that could be transferred from a line of credit to cover an overdraft, or by an amount that could be transferred from another account of the consumer to cover an overdraft -- collectively referred to as "overdraft funds"). The balance can reflect holds placed under Reg CC for delayed availability of deposits by check, funds that have been memo posted to or from the account for ACH activity or pending deposits or checks taken at the teller line, etc.

2. In addition to that balance, you can provide a separate balance that includes "overdraft funds" if you prominently label it to indicate it includes overdraft funds.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#1298181 - 12/03/09 06:36 PM Re: Reg DD Revisions & Change-in-Terms Notice John Burnett
CSB98 Offline
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Joined: Dec 2003
Posts: 1,362
Wisconsin
Can someone direct me to the actual ruling on the Reg. DD changes? I can't seem to find it anywhere.

Never mind, I found it.
Last edited by CSB1; 12/03/09 06:48 PM. Reason: Found what I was looking for
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