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#1895055 - 02/07/14 07:35 PM Opt-in and termination of Overdraft Program
Likes to Comply Offline
Diamond Poster
Joined: Nov 2008
Posts: 1,109
In the mountains
If a customer opts in to the payment of one time POS and ATM transactions in conjunction with our overdraft program, if for some reason the overdraft program is suspended and then later reinstated, should we provide another opt-in disclosure for the customer to sign? Technically, they have not revoked the previous opt-in, even though when the overdraft program is suspended the account is changed so that it will not pay and assess a fee on one-time POS and ATM transactions that overdraw the account.
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Operations Compliance
#1895173 - 02/07/14 09:39 PM Re: Opt-in and termination of Overdraft Program Likes to Comply
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
There is no regulation where you can look up a question like this. Pretending for the moment that I'm an examiner I will drink deeply from their well of ephermal wisdom and say :

If you told the customer that the program was terminated it would be necessary to start anew i.e. provide any necessary disclosures and solicit an opt-in.
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#1895175 - 02/07/14 09:42 PM Re: Opt-in and termination of Overdraft Program Likes to Comply
Likes to Comply Offline
Diamond Poster
Joined: Nov 2008
Posts: 1,109
In the mountains
Thanks for the help!
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