Has anyone had a delay in implementing opt-in-out due to a vendor problem? We are being told by our ATM driver that they cannot activate our customer's access to thier overdraft protection at ATM's & for one time pos debits until Aug. 25th and they want to push it back to Sept.1, 2010. We have sent out the required notices and confirmations and updated our systems to reflect the choices. I am at a loss as to how to proceed at this point. Do we need to do a mass mailing to inform the customers that there has been a delay (if I can get a firm date)? I have a call into our Regulator also. Your input/guidance is greatly appreciated.

Ours was governed by our core processing system.

Allsmiles I sent you a PM

repsonded to your pm mck.
Shush our core processor is good to go. It is the ATM driver that seems to be causing the delay.

You've sent the notice and some customers opted-in. As I understand it, the problem is with your vendor being able to facilitate the overdraft via ATM & debit card transactions; they cannot. Any overdraft generated by "plastic" would essentially be inadvertent on the part of your bank.

The problems seem to be 1) the potential loss of revenue and 2) the fact that some customers who want to overdraw their account will not be able to.

Your opt-in customers gave you permission to overdraw their accounts via plastic. You never promised that you would do so.

You may have a public relations problem, but you do not have a compliance problem. I suggest you just casually notify your opt-in customers that you have experienced some unexpected delays on the technology side and expect the system to be fully functional on XX date. (Your letter will be an advertisement under Regulation DD, include all of the extra junk.)

I would not discuss it with my regulator; this is a business decision, not a compliance decision and you should know a lot more about that than they do...

Thank you!