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?

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.

Randy - when you say an ODP would this include an Ad Hoc program? Or does it need to be a formalized ODP?

It has to be a formalized ODP program

Thank you Randy.