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#2206455 - 02/19/19 03:47 PM EFT Good Funds Processing
ComplianceNewby Offline
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ComplianceNewby
Joined: Feb 2014
Posts: 109
Louisiana
Is anyone else using the EFT Good Funds Processing on their core system for ATM, one-time POS and PayNet debits authorized against good funds so that overdraft fees are not automatically applied by return item processing ? If so, if you have the ability to manually add an OD fee in return item processing, are you doing this? We have the ability to manually add an OD fee, but I am concerned we could end up in a situation depending on how we choose which ones to manually add an OD fee to and which ones we don't.

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#2206456 - 02/19/19 04:08 PM Re: EFT Good Funds Processing ComplianceNewby
rlcarey Online
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rlcarey
Joined: Jul 2001
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Galveston, TX
For those of us not familiar with EFT Good Funds Processing, you might have to explain further. I assume you are only talking about customers that have opted-in?
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#2206466 - 02/19/19 04:29 PM Re: EFT Good Funds Processing ComplianceNewby
ComplianceNewby Offline
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ComplianceNewby
Joined: Feb 2014
Posts: 109
Louisiana
With EFT Good Funds Processing, the Reg E accounts with an accepted decision do not assess an OD fee if the EFT ATM, one-time POS, or PayNet debit transaction was authorized against good funds or else a positive balance which does not include the OD limit. So basically it was authorized on good funds, but when it settles, the account is overdrawn. So the system won't charge them an OD fee. But it does allow you to manually add an OD fee.

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#2206482 - 02/19/19 07:32 PM Re: EFT Good Funds Processing ComplianceNewby
John Burnett Online
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John Burnett
Joined: Oct 2000
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Cape Cod
"Good funds," I assume, is the rough equivalent of "available balance" (how I wish there were a regulation requiring the user of a standard set of terms for such things!). And regulators made a big stink at the end of 2016 over banks that used available balance for approving/disapproving ATM and one-time POS debits, reduced the available balance by the amount of any approved ATM or one-time POS authorization and then determined whether the account is overdrawn (triggering an OD fee) based on available balance.

I can't help but assume the "good funds" processing is concocted to assuage the concerns of those regulators.
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