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#1622404 - 10/31/11 08:59 PM od fees on savings accounts
notuntermywatch Offline
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Is there an exemption for savings accounts for the OD rules 205.17?

For example, customer has not opted-in, savings account, ATM withdrawal overdraws the account...can we charge a overdraft fee?

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#1622408 - 10/31/11 09:07 PM Re: od fees on savings accounts notuntermywatch
Doug Hendrickson Offline
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I don't believe there is an exemption. In fact, under the definitions (205.2), savings accounts are identified in the meaning of 'account' for purposes of the regulation. Since it was an ATM withdrawal that caused the overdraft, you cannot charge an overdraft fee if the customer has not opted-in.
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#1622556 - 11/01/11 01:51 PM Re: od fees on savings accounts Doug Hendrickson
John Burnett Online
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I'll second Doug's opinion. No opt-in, no fee.
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#1622669 - 11/01/11 03:42 PM Re: od fees on savings accounts John Burnett
notuntermywatch Offline
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That's what I thought, but I'm getting a different answer from a major core processor that doesn't give an option to program an opt-in/opt-out on the savings platform. I'm just wondering how that could be...don't answer that smile

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#1622673 - 11/01/11 03:45 PM Re: od fees on savings accounts notuntermywatch
John Burnett Online
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Major core processor isn't apparently tuned in to the real world too well. To be fair, not all banks have OD fees on savings accounts. But the vendor ought to realize that many would have such fees and that savings accounts are just as subject to Reg E as are transaction accounts.
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#1622815 - 11/01/11 05:29 PM Re: od fees on savings accounts John Burnett
Elwood P. Dowd Offline
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If the vendor allows you to charge fees for overdrafts on savings accounts, I would categorize the related Regulation E related programming as being required by "compliance;" i.e. you are not asking for an enhancement that you should be asked to pay for.

As Doug demonstrated, Regulation E's application does not turn on whether the account is a transaction or savings account.
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