Is there a regulation covering how to calculate date overdrawn? Can a service fee trigger resetting the last date overdrawn? Example: Account has $5 balance. Service fee takes it into the negative. Is that account now considered overdrawn if the negative balance is due to a bank imposed service fee, and does the 60 day countdown to charge off begin due to the bank imposed service fee?

The biggest question is the regulation reference, is there one I can use to bring weight into this debate? I will continue searching on my own but certainly appreciate any assistance.

Whether through a debit initiated by the customer or a debit to the account imposed under the depositor's agreement, I am not sure what difference it would make and I doubt that you are going to find anything.

What does your deposit contract/agreement say? Does it provide for the charging of an OD fee when a bank fee takes an account negative? From a regulatory perspective, you're going to pull the UDAAP trigger if you don't disclose it if that's what happens.

But from a date OD perspective, what difference does it make what transaction took the account into sub-zero territory. It went negative, and if it doesn't return to positive, you will have a charge-off in 45 (CUs) or 60 (others) days.

Thank you, rlcarey and Mr. Burnett. I appreciate both of your insight. This was the outcome I suspected, but none the less, thank you very much!