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#1369099 - 04/05/10 01:32 PM Notice of OD ATM Screen
CompDat Offline
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Joined: Dec 2005
Posts: 553
I was told that we have to provide notice now at the ATM screen that the customer is about to generate an overdraft. I cannot find this in 205.17. I recall something similar to this from the old OD rules, but that was if you were advertising ODs. Any thoughts?

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#1369301 - 04/05/10 04:17 PM Re: Notice of OD ATM Screen CompDat
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,684
Cape Cod
It harkens back to the best practices listed in the February 2005 ODP guidance. The Fed has recently said that it feels the best practices are still best practices (unless regulations have superseded them). It probably can only work at your own ATMs, but it's also wise to post a notice at the ATM to the effect that ATM transactions that overdraw an account may result in OD fees.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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