Not unless it involved an UDAAP issue that involves post order or something like that. The problem with basing ODs on available balance is the difficulty in explaining how that is calculated. If I have someone place a large hold on funds because I gave them a debit card (for example, I rent a car and they place a $600 hold on my account and I then pay cash when I return the car) and that debit never materializes, you could be charging me for ODs that will never happen.
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