The intent of the rule is that the customer be made whole with respect to unauthorized EFTs that the bank must reimburse the customer for. So any overdraft fee that would not have been charged if the unauthorized EFT had not happened should be reversed, regardless of how separated in time the unauthorized EFT was from the OD fee.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8