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#2135700 - 06/23/17 08:29 PM Reg E - Opt In Revoked
Mel in WA Offline
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Joined: Mar 2013
Posts: 1,265
When a customer opts-in to include debit card and ATM transactions into overdrafts, we send a confirmation letter that includes information on how to revoke this decision. When they revoke (cancel) the opt-in, are we required to send a confirmation notice? It doesn't seem to be required per the regulation, (1005.17(f)), but I'm thinking it may be a good business practice.

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eBanking / Technology
#2135967 - 06/27/17 01:27 PM Re: Reg E - Opt In Revoked Mel in WA
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
And I agree with you. When it comes to overdrafts and overdraft fees, improved communication and transparency with the customer is a definite plus. I suggest you confirm that the opt-in has been cancelled, remind the customer of the potential for being rejected at an ATM or point of purchase, and explain how to opt back in (subject to approval, of course).
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#2145289 - 09/08/17 01:23 PM Re: Reg E - Opt In Revoked Mel in WA
peony Offline
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peony
Joined: Mar 2013
Posts: 250
Bringing this up: We don't send a confirmation letter when they opt in. They get a copy of the form (the model form provided by CFPB) they signed when they opt in. If we are using their form and that's what they receives as their confirmation, should we add the 'right to revoke' language in the form?

Thanks.

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#2145292 - 09/08/17 01:43 PM Re: Reg E - Opt In Revoked Mel in WA
peony Offline
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peony
Joined: Mar 2013
Posts: 250
I think I found my answer - Under 1005.17(d)(6), we can modify the form to include the right to revoke consent language if we uses the form as the confirmation.
Last edited by peony; 09/08/17 01:44 PM.
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