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#1402004 - 06/10/10 05:51 PM 6 Transaction per statement cycle on Stmt Sav
Kahola Offline
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Kahola
Joined: May 2001
Posts: 712
Scottsdale, AZ. 85255
A customer can have their savings account linked to a checking account for overdraft protection. We have a customer that has had more than the 6 trans. per statement cycle. We took away the link after 3 warnings. Once the link is gone how long do we need to wait until we could add the link back? 6 Months, 1 year???

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#1402125 - 06/10/10 07:32 PM Re: 6 Transaction per statement cycle on Stmt Sav Kahola
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
There's nothing specific in the regulation or in the comments the Fed has published about the rule. However, that doesn't mean you can't give access back after whatever you deem to be a suitable time -- I'd suggest it has to be at least a couple of months -- but I would only do so if you have a well-defined and strict policy for doing so. This is not something I would allow your branches to administer; it needs to be centrally managed. I do think you need to let the customer know there will not be a "three strike" allowance this time around. Stepping beyond the limits in one month ought to be sufficient to pull the plug the next time, and there should not be a third chance for the customer.

Please note that all of that is my opinion. It hasn't been blessed by any regulator that I'm aware of.
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John S. Burnett
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#1402146 - 06/10/10 07:54 PM Re: 6 Transaction per statement cycle on Stmt Sav John Burnett
Kahola Offline
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Kahola
Joined: May 2001
Posts: 712
Scottsdale, AZ. 85255
Thanks John.

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