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#2119654 - 02/27/17 07:20 PM Reg DD - Disclosing Transactions that May Cause OD
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,211
The West
Does this section of Reg DD apply to account opening disclosures when a bank does NOT offer an overdraft service covered by Reg E?

FEES FOR OVERDRAWING AN ACCOUNT.
Under § 1030.4(b)(4) of this part, institutions must disclose the conditions under which a fee may be imposed. In satisfying this requirement institutions must specify the categories of transactions for which an overdraft fee may be imposed. An exhaustive list of transactions is not required. It is sufficient for an institution to state that the fee applies to overdrafts “created by check, in-person withdrawal, ATM withdrawal, or other electronic means,” as applicable. Disclosing a fee “for overdraft items” would not be sufficient.

If it does apply, I would be interested to know how anyone using Wolters Kluwers forms discloses it. It appears that the template language in the lower right column on the first page may be intended for this disclosure. Can you confirm?
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General Discussion
#2119689 - 02/27/17 08:52 PM Re: Reg DD - Disclosing Transactions that May Cause OD TryingtoComply
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The disclosure is required regardless of whether the bank operates an overdraft service.
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#2119728 - 02/28/17 12:34 AM Re: Reg DD - Disclosing Transactions that May Cause OD TryingtoComply
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,211
The West
Yeah, I figured that out after I posted. We disclosed it in the schedule of fees and charges section at my last bank, so I was thrown off a little. I think banks insert the language in different places.

Thank you Ken for responding!
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