Legally, as long as the kid is an adult, I see no problem. In some states and under limited conditions, it might be legally OK for a minor, although I think I'd steer clear.
Last edited by John Burnett; 08/01/12 05:18 PM. Reason: oops
I'd be very wary of offering ODP protection in the form of an overdraft payment program for students unless you had very low limits, a generous de minimis provision and a tight (low) fee cap. I'd also monitor the heck out of it to ensure the student doesn't abuse (or become abused by) the program.
With the CFPB's current focus on the costs of education and overdraft programs, promoting an overdraft payment program for students might be the equivalent of throwing gasoline on a bonfire.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8