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#351028 - 04/25/05 06:43 PM What's included in your ATM balance?
BBoyd Offline
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BBoyd
Joined: Mar 2002
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MI
When your customers do a balance inquiry on your bank's ATM, what balance do they see?
single choice


Votes accepted starting: 04/25/05 06:40 PM
You must vote before you can view the results of this poll.
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Operations Compliance
#351029 - 04/25/05 07:31 PM Re: What's included in your ATM balance?
Elwood P. Dowd Offline
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Next to Harvey
I don't want to hi-jack BBoyd's thread and hope I'll be forgiven for making an ancillary point. The adjectives "current," "ledger," "collected," and "available" when applied to the balance don't have a universal meaning among bankers. Prior thread. They cannot be relied upon to have a universal meaning to customers.

When your bank is attempting to comply with the ODP Guidelines, developing forms, disclosures and notices you will be working without a net; i.e. you will be working without model disclosures or clauses for the first time in a long time. Every examiner will be entitled to say that whatever language you have chosen is unclear. The ATM language is a prime example.
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#351030 - 04/26/05 01:02 PM Re: What's included in your ATM balance?
P*Q Offline

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P*Q
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Somewhere
We show 2 balances-collected (current) and available (includes any OD protection amount as well). That option wasn't available to vote on.

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#351031 - 04/26/05 01:20 PM Re: What's included in your ATM balance?
John Burnett Offline
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Cape Cod
Quote:

We show 2 balances-collected (current) and available (includes any OD protection amount as well). That option wasn't available to vote on.




Which leads to the next question: Does the screen make it clear that "available" includes the ODP amount?
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#351032 - 04/26/05 03:27 PM Re: What's included in your ATM balance?
P*Q Offline

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P*Q
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Somewhere
The screen does not but we have a sign right next to the screen that tells them the ODP is included in avail. balance, is this sufficient.

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#351033 - 04/26/05 04:12 PM Re: What's included in your ATM balance?
John Burnett Offline
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Probably. That's a heck of a lot more than some banks were doing when providing the ODP-inclusive balance. Nice way to handle it.
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#351034 - 04/26/05 04:44 PM Re: What's included in your ATM balance?
BBoyd Offline
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MI
Agreed! And Ken, you didn't hi-jack it at all; I appreciate the clarification. We recently had a situation where a customer checked his balance just after he had made a deposit that showed up as a memo-post to his ATM balance (we're looking into that, as it wasn't cash...). So - of course, he spent money that wasn't available and well...you know the rest.... We're trying to determine the best balance - or best method of communicating the balance - so all understand. I like Pizzaz's idea of the sign.

And you're so right - the definitions vary, and I tried to present as many scenarios as I could....
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#351035 - 04/26/05 05:22 PM Re: What's included in your ATM balance?
rlcarey Online
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Galveston, TX
What is displayed to the customer when they are using foreign ATMs?

Always the devil's advocate
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#351036 - 04/26/05 07:55 PM Re: What's included in your ATM balance?
Anonymous
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We have a sign on our ATMs stating the ODP amounts are included in the available balance. During our compliance exam three weeks ago, the examiner said this was sufficient.

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#351037 - 04/26/05 09:55 PM Re: What's included in your ATM balance?
Anonymous
Unregistered

What does ODP stand for? Or am I the only stupid one?

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#351038 - 04/26/05 09:56 PM Re: What's included in your ATM balance?
SHORT STUFF Offline
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Overdraft Protection

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#351039 - 04/26/05 10:18 PM Re: What's included in your ATM balance?
Jokerman Offline
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Quote:

What does ODP stand for? Or am I the only stupid one?




You're not stupid for not knowing an acronym. But if you ARE stupid, I have mountains of evidence that you are not the only one.

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#351040 - 04/28/05 06:55 PM Re: What's included in your ATM balance?
Anonymous
Unregistered

We also give two balances; current and available (which included their bounce limit). We have a sign on each of our ATM's that says the available balance may include their bounce limit. However, our regulators have suggested at the last two exams that we should pull the available balance because we can't give them notice at POS or foreign ATM's. Has anyone else had this recommendation?

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#351041 - 04/28/05 08:51 PM Re: What's included in your ATM balance?
Jokerman Offline
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Quote:

However, our regulators have suggested at the last two exams that we should pull the available balance because we can't give them notice at POS or foreign ATM's. Has anyone else had this recommendation?




I understand the comment about foreign ATMs. But can they obtain a balance at a POS?

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#351042 - 05/02/05 08:53 PM Re: What's included in your ATM balance?
Creditcopper Offline
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Michigan
Quote:

Quote:

However, our regulators have suggested at the last two exams that we should pull the available balance because we can't give them notice at POS or foreign ATM's. Has anyone else had this recommendation?




I understand the comment about foreign ATMs. But can they obtain a balance at a POS?




Our vendor is Pinnacle and we use M&I for processing. At both foreign ATMs and POS locations M&I will only provide one balance option to the customer so we have their "available" balance provided to them that includes whatever ODP balance they may have. I don't know about other vendors, but we're at the mercy of M&I and NYCE as far as a second pop up screen for those transactions.

I should preface this post with the fact that we don't have an active product yet, we're in the phase of getting the structure and operations ready for a roll out.

If I can ask, the poster who mentioned their regulator wanted them to remove the current balance option because they can't provide it at foreign ATMs, what if you provided the "available" balance instead? Did they comment on that?
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#351043 - 05/03/05 02:36 AM Re: What's included in your ATM balance?
John Burnett Offline
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The regulatory concern is that consumers might be getting misleading information if they are not aware that the balance being displayed includes the ODP line. Same with POS and other authorizations normally done against book balances. The most conservative approach is to use an adjusted ledger balance (net of any holds or memo posts placed during the day).
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#351044 - 05/03/05 11:05 AM Re: What's included in your ATM balance?
Elwood P. Dowd Offline
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Next to Harvey
At the risk of over simplification, I would start with the concept that if you only show one balance that it should not include the ODP amount. Some of those posting above skirt that prohibition (effectively in my mind) by posting a notice on the machine that the balance shown does include the ODP amount. Anon #357050's regulator says that is misleading to his customers when they use a foreign ATM; i.e. they won't be reminded that the balance shown includes ODP.

Regardless of the effect on his own customers, as Mr. Carey suggests, Anon #357050's notice may be clearly misleading to a noncustomer who uses his ATM because her bank does not include ODP in the balance shown.

Personal opinion: As noted above, including the ODP amount in the balance can cause confusion for the consumer. It is also an inducement to overdraw the account that is common only to this product; e.g. if a customer's account is backed by a HELOC what banks consider adding that $5,000+ to the balance shown for the account on an ATM? Only as opinion and not as an interpretation of the Guidance, I don't think the ODP amount should be incorporated into any figure given to the consumer.

I regard the lesser evil to be a notice or a preprinted ATM receipt that says, "The balance shown does not include the amount of any overdraft protection amount which we may have assigned to your account." This should satisfy Anon #357050's regulators. However, once again, the noncustomer using his ATM becomes an acceptable casualty in the ODP wars because her bank does include ODP in the amount shown.

Overall, I don't think ODP is a "bad" product, but it does bring out our industry's predatory instincts and routinely forces us to navigate between the Scylla and the Charybidis.

P.S. Remember, the Reg DD changes are hanging fire. With a little torturing of what constitutes "advertising" they could simply prohibit banks from incorporating the ODP amount into any figure quoted to the customer.

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#351045 - 05/06/05 07:47 PM Re: What's included in your ATM balance?
Anonymous
Unregistered

I was under the impression that there may be some other rules (regulations) that may apply here. I am not sure which ones they are at the moment but I am sure that I have read that you must display the balance that you "pay" from. So if your daily payments are paid only from your "collected balance" then you must at least state this balance. We pay from the "available balance" and that is what we display at foreign ATM's. Our own ATM's we display both and we have a message on the receipts letting our customers know that this may include you overdraft privilege limit.

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#351046 - 05/25/05 05:27 PM Re: What's included in your ATM balance?
ldsnanny3 Offline
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ldsnanny3
Joined: Nov 2003
Posts: 205
Georgia
So, is this correct, if we show just the current balance to the customer at the ATM machine, and the customer conducts a transaction that causes him to access the OD protection, do I need to have a notice posted at the ATM informing the customer that accessing the OD protection could trigger NSF fees to be charged to them?

Please help me with this wording.
Thanks

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