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#2202241 - 01/07/19 09:23 PM Checkless Checking- Auto Opt Out for ATM and Debit
M&M Offline
Platinum Poster
Joined: Nov 2003
Posts: 527
Midwest
Many banks are targeting the unbanked and/or underbanked with a checkless checking with no overdrafts. Is it permissible to automatically opt out customers from paying ATM and one-time debit transactions as an account feature and not give them the option to opt-in, all in an effort to avoid overdrafts on the account? I believe this is permissible, but I'd like confirmation.

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#2202242 - 01/07/19 09:28 PM Re: Checkless Checking- Auto Opt Out for ATM and Debit M&M
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,085
Illinois
Since paying overdrafts is discretionary, there is certainly no requirement forcing you to offer overdraft services for one-time ATM/debit card transactions.
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#2202522 - 01/09/19 10:42 PM Re: Checkless Checking- Auto Opt Out for ATM and Debit M&M
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,416
Cape Cod
Amen on that. And if you DO allow overdrafts in the face of marketing the account as one without ODs and OD fees, you could have problems.
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