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#1445933 - 09/21/10 05:10 PM Reo O - Overdraft
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Joined: Jun 2008
Posts: 287
Is a daylight overdraft an extension of credit under Reg O? The language of the regulation seems to say that, but want to see if there are other opinions.

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#1446283 - 09/21/10 11:12 PM Re: Reo O - Overdraft Random
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
"EXTENSION OF CREDIT"--Negative Bank Account Balance

The negative balance on a zero-balance account is an overdraft and therefore an extension of credit, unless the negative balance qualifies as an inadvertent overdraft. This is unaffected by the existence of funds in a second account of the account holder, unless the bank has written authorization from the account holder to charge the second account and that account is actually charged in the amount of the overdraft. However, a negative balance outstanding for 24 hours or less would not constitute an overdraft where funds are being automatically or electronically deposited or transferred.

A check drawn and paid against uncollected funds is neither an overdraft nor an extension of credit. It becomes an extension of credit if it is returned to the bank uncollected and does not qualify as an inadvertent overdraft. STAFF OP. of May 4, 1979.
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#1515536 - 02/28/11 07:32 PM Re: Reo O - Overdraft rlcarey
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Joined: Aug 2005
Posts: 223
Do you know where I can get a copy of this citation? I would like to have something in my hands before I give the okay to pay an overdraft on a Director's account with a pending electronic deposit.

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#1515552 - 02/28/11 07:45 PM Re: Reo O - Overdraft Comply101
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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