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#562044 - 06/05/06 02:31 PM Reg DD changes on telephone banking
Simply Sheldon Offline
Diamond Poster
Simply Sheldon
Joined: Oct 2005
Posts: 2,047
When a customer calls for their balance on our telephone banking it provides their current and available balance. Should the system define and disclose that the available balance is their overdraft and that it is subject to our standard overdraft fees. Our institution promotes overdraft and defines the new conditions in the initial pamphlet, discloures, and on statements.

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#562045 - 06/13/06 05:12 PM Re: Reg DD changes on telephone banking
Dip Offline
Power Poster
Joined: Mar 2005
Posts: 6,298
San Diego, CA
i woudl say include overdraft in the available balance sounds ridiculous to me and if not disclosed out in the open, will confuse a lot of customers. especially if you charge fees to use overdraft, make it very obvious to the customer!
Dabbling in banking, law, accounting...the life of a trustee.

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#562046 - 06/13/06 07:53 PM Re: Reg DD changes on telephone banking
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,641
Cape Cod
No value judgments here: If any balance that you provide on your Telephone Response Unit (sometimes called a Voice Response Unit) includes the customer's ODP protection cushion, the Guidelines suggest that you separately identify their actual (non-cushioned) balance and clearly identify which is which. If you do provide the "padded" balance, you need to add to the message the fees that can be charged on an overdraft (not just the one-time fee, but include any other overdraft fees like "interest" or charges for remaining OD more than X days, etc.; PLUS you need to tell the customers how quickly they are expected to "cure" the overdraft.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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