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#2251593 - 03/31/21 05:44 PM Overdrafts
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
We are reviewing our overdraft service. We offer Overdraft Defender where customers get a preassigned OD limit. We have the customer sign form at account opening if they want or decline the service. In addition, we also give the Reg E opt in form for their debit card and ATM transactions.

I’m curious to see how others handled enrollment that has a program similar to ours. It sometimes gets confusing with two forms. I've seen some banks where they OD service is automatically given at account opening and then only use the Reg E form.

Thanks for any feedback!

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#2251598 - 03/31/21 05:50 PM Re: Overdrafts ahkcompliance
Bankwoman1 Offline
Diamond Poster
Joined: Dec 2015
Posts: 1,064
Midwest
Our overdraft service is automatically provided on our checking accounts. We do provide a disclosure to the customer detailing the service but they do not have to sign anything. If the customer declines the service, then we have them sign a maintenance form stating they do not want our OD service. Customers that do keep the service on their account are provided a Reg E form to opt in or out of ODs on ATM withdrawals and one time debit card purchases.

If we deny a customer the OD service due to information we obtain from our ChexSystems search, but still open an account, we provide them with an Adverse Action Notice.
Last edited by Bankwoman1; 03/31/21 05:51 PM.
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#2251600 - 03/31/21 05:54 PM Re: Overdrafts ahkcompliance
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
ok, thank you!

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