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#1655940 - 01/25/12 07:56 PM Reg E opt-in Delay
JBanker28 Offline
Member
Joined: Apr 2006
Posts: 57
Kansas
Currently, our core processor is taking 2 days to process a Reg E opt in. I'm not finding any citations that say this must be immediate, but I was sure that was the intent. Does anyone know if this two day delay will get us into trouble?

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#1655985 - 01/25/12 08:41 PM Re: Reg E opt-in Delay JBanker28
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
When your customer opts in you are not promising to take them overdrawn. If the customer opts in on Tuesday and initiates a one time ATM transaction on Wednesday that would create an overdraft, you are not obligated to pay it.

Your argument to your processor is that the delay might cost you fees, not that it violates some regulation or regulatory intent.
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#1655987 - 01/25/12 08:30 PM Re: Reg E opt-in Delay JBanker28
JBanker28 Offline
Member
Joined: Apr 2006
Posts: 57
Kansas
ok. Thank you!

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