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#2253706 - 05/10/21 01:56 PM Repeated Overdraft Hold - Reg. CC
TeamComply Offline
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Joined: Aug 2016
Posts: 393
Under Repeated Overdrafts exception hold information found at 229.13(d) it states that:

"(d) Repeated overdrafts. If any account or combination of accounts of a depositary bank's customer has been repeatedly overdrawn, then for a period of six months after the last such overdraft, ยงยง229.10(c) and 229.12 do not apply to any of the accounts."

The statement "then for a period of six months after the last such overdraft..." does this mean that once characterized as repeated overdraft, this exception hold reason could be used for up to 6 months later??

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#2253751 - 05/11/21 02:56 PM Re: Repeated Overdraft Hold - Reg. CC TeamComply
rlcarey Offline
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rlcarey
Joined: Jul 2001
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Galveston, TX
You can use it for six months after an overdraft by the customer meets one of these thresholds.

(1) On six or more banking days within the preceding six months, the account balance is negative, or the account balance would have become negative if checks or other charges to the account had been paid; or

(2) On two or more banking days within the preceding six months, the account balance is negative, or the account balance would have become negative, in the amount of $5,525 or more, if checks or other charges to the account had been paid.

Of course this is a rolling assessment, so if they continue to have overdrafts, you can reassess that six month period.
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#2253799 - 05/12/21 02:03 PM Re: Repeated Overdraft Hold - Reg. CC TeamComply
John Burnett Offline
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John Burnett
Joined: Oct 2000
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Cape Cod
Let's suppose that in May you review a chronically overdrawn customer's transaction account(s) and find that during the prior 6 months they met one of the two criteria that Randy lists above ^^^. You can treat that customer's accounts as subject to the "repeated overdrafts" rule for six months, starting from the customer's most recent overdraft incident.

At the end of that six-month period, review the account(s) again for overdrafts during that period. If they don't meet either criterion, you end the "repeated overdrafts" status. If they do meet one or both of the criteria, you may extend the "repeated overdrafts" status for a new 6-month period.

Of course you always have the option to end the relationship.
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