Our bank has an ad hoc program and we do not offer the opt-in for ATM and POS transactions. However, management is contemplating on making the ad hoc decisions more consistent between the branches. For example, if the customer has a credit score of 750 and above, we'll pay up to this much, if they have a score above 650, we will overdraw them this far. Of course, in saying that, there are other factors they look at (i.e. length of time as a customer, existing overdrawn experience, etc.) It's not a program, it's just to help the branches be more consistent. Is this considered a program if we do that? Would we have to disclose this information to the customer? Would we have to have a policy and procedures? Thank you.