Not sure everyone is aware of this...because I wasn't! It was in a recent ICBA email. A proposal to amend TIL to include the overdraft programs.. http://www.gpo.gov/fdsys/pkg/BILLS-112hr5691ih/pdf/BILLS-112hr5691ih.pdf

I haven't seen this, nor read anything else about it.

When this "product" first came out 6 or 7 year ago there are several of us that predicted the product would eventually be brought in under the Reg Z umbrella therefore this action is no surprise to me.

I believe these proposed amendments are very similar to the OCC's proposed guidance on OD Programs that came out last year (or 2010) and were never finalized.

Dan my first bank offered this "program" before I started there in 1983. It has been around a long time but really gained popularity 10 years ago. I think the perceived regulatory abuses were discussed then and came into more regulatory control in your 6 or 7 year time frame.

I hadn't heard of this either and wonder what the chances are that it will pass in the House and the Senate?