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#2221817 - 09/18/19 02:38 PM ODP Transfer form
BJ Blazko Offline
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Joined: Apr 2016
Posts: 20
Is it necessary to have a customer sign a form for setting up overdraft protection transfers (e.g. auto transfer from savings to checking in the event of an overdraft) or can we just set it up in our system without a signature?

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Operations Compliance
#2221818 - 09/18/19 02:41 PM Re: ODP Transfer form BJ Blazko
Sunshine Lady Offline
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Joined: Apr 2014
Posts: 590
We require a signature so that we have something showing that the customer authorized the service in case there are problems down the road, but I would think it would be a bank call.
Define Success on your own terms, achieve it by your own rules, and build a life you are proud of. Anne Sweeney

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#2221819 - 09/18/19 02:44 PM Re: ODP Transfer form BJ Blazko
BrianC Online
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Joined: Nov 2004
Posts: 6,079
Purely a legal question, but consider what you do when a customer claims that they didn't authorize you to make a transfer, or you charge a fee for the service the customer claims they never asked for.

I'm not an attorney, nor do I play one on the internet, but I'm going to say that you want some way of documenting that your customer authorized the sweep arrangement.
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!

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#2221827 - 09/18/19 03:23 PM Re: ODP Transfer form BJ Blazko
HappyGilmore Offline
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Joined: Jun 2004
Posts: 19,336
Pulling people out of the ditc...
we require a signature or e-signature for any change to products or services, which would include adding or eliminated ODP.
Providing alternative truths since the invention of time

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#2221832 - 09/18/19 03:53 PM Re: ODP Transfer form BJ Blazko
P*Q Offline

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Joined: May 2001
Posts: 8,439
Totally agree with Brian, why open yourself up to a customer claiming they didn't authorize.

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#2222159 - 09/23/19 08:13 PM Re: ODP Transfer form BJ Blazko
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,409
Cape Cod
Too many frauds have involved a crook (sometimes a family member) getting access to online banking and moving money from savings to checking and then out via a wire or ACH transaction. A signature on a retained authorization is a good CYA move.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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