We currently allow customers to access their Overdraft Protection(formal line of credit) with debit cards. A Bank Attorney advised that we should change our billing for Overdraft Protection to be in compliance with the Credit Card Act of 2009. Does this mean our debit card customers have to also be in compliance with the Credit Card Rules effective February 22, 2010 that include the requirement to have a debit card, the account holder under age 21 would need proof of repayment ability or a Co-Signer?

Beginning on Page 26 of the Reg Z final rule that was released on January 12, 2010, it discusses how the Board determined that overdraft lines of credits and overdraft protection programs accessed by a debit card are exempt.