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#2183553 - 06/28/18 05:58 PM Overdrafts
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,470
Midwest
There is FIL 11-2005 regarding charging overdrawn accounts off at 60 days. Does anyone know if this is still valid? I have discovered an account overdrawn for 200+ days. The reason I was told was they are paying back. We have entered into a repayment agreement. Their SS money goes in each month and we take it. I don't think we should keep the account on the system but my retail person tells me if we close it then we wont get our money.

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Deposits and Payments
#2183561 - 06/28/18 06:21 PM Re: Overdrafts ahkcompliance
Skyline Offline
Platinum Poster
Skyline
Joined: Sep 2005
Posts: 589
Page 7 from the FIL you referenced:
In some cases, an institution may allow a consumer to cover an overdraft through an extended repayment plan when the consumer is unable to bring the account to a positive balance within the required time frames. The existence of the repayment plan, however, would not extend the charge-off determination period beyond 60 days (or shorter period if applicable) as measured from the date of the overdraft. Any payments received after the account is charged off (up to the amount charged off against allowance) should be reported as a recovery.

If the repayment plan contains more than 4 installment payments, you may also have a Reg. Z issue. Is there a way you can charge off the account balance without closing the account?
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