I'm hoping someone here can help me. I'm running a meeting on this next week and I've already written a detailed 7-page summary of the changes. I thought I had it all figured out and then someone stumped me with a question. I've read that thing multiple times, so I am either missing the answer (very possible) or it's not something that was discussed or finalized.
Question - for existing customers who ARE enrolled in some kind of an OD protection program (checking linked to savings, customer opened an OD protection line of credit, etc.) - how do we handle the opt-in process for them?
To clarify, we will be notifying all customers (new and existing) of the opt-in, as required. A senior manager asked - "What if someone doesn't opt in, but they have OD protection? Are we allowed to charge them the small transfer fee that occurs if they OD their account with an ATM or one-time debit card transaction? Are we allowed to even authorize that transaction if the money is not available in their account?"
These people are used to having this OD protection and so I don't believe we can just start declining their transactions.
So how do we handle this? Do these people HAVE to opt-in in order for us to accomodate them? Or do we explain in our notice to existing customers that the opt-in requirement does not apply to them if they are already enrolled in an OD protection program?
Also, what if we pay the ODs and make the OD transfer from savings and then charge them the $7.50 fee - can they complain and use Reg E to justify that they should not be charged since they didn't opt in?
Head spinning.... Most likely I am overthinking it and the answer is right in front of me. Any help would be greatly appreciated!
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CRCM + CAMS = certified compliance nerd
Opinions expressed in these threads are my own and not my employer's.