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#2255998 - 06/25/21 08:30 PM Reg E Opt-In Model Notice
ACBbank Offline
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ACBbank
Joined: Jul 2006
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New York City
I have a question about the A-9 Model Consent Form for overdrafts. Is it required to provide this form? If a bank decides to avoid authorizing and paying ATM and one-time debit card transactions that would overdraw a consumer's account, can the form be avoided? If so, if the Bank does decide to pay a covered transaction that overdraws an account, a fee cannot be charged at all?
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#2256008 - 06/25/21 09:35 PM Re: Reg E Opt-In Model Notice ACBbank
rlcarey Online
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rlcarey
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Posts: 77,247
Galveston, TX
Well, you have to have an overdraft protection program first. Then you can decide if you want to offer an opt-in. You are not required to, but as you point out, you could not charge an OD fee on those transactions if you don't do both.
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#2256009 - 06/25/21 09:42 PM Re: Reg E Opt-In Model Notice ACBbank
ACBbank Offline
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New York City
Randy - when you say an ODP would this include an Ad Hoc program? Or does it need to be a formalized ODP?
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#2256011 - 06/25/21 09:54 PM Re: Reg E Opt-In Model Notice ACBbank
rlcarey Online
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rlcarey
Joined: Jul 2001
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Galveston, TX
It has to be a formalized ODP program
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2256012 - 06/25/21 10:02 PM Re: Reg E Opt-In Model Notice ACBbank
ACBbank Offline
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ACBbank
Joined: Jul 2006
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New York City
Thank you Randy.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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