I know this is a hotly debated topic right now, however I am charged with a task....

My bank is exploring the possibility of allowing access to the bank's overdraft protection program at the ATM. The ODP guidelines state that if an on-screen notice is not feasible, then it is acceptable to post notices on the ATM that explain that transactions may be approved that overdraw the account and fees may be incurred. If I am understanding the guidance and rules correctly, then the amount of the fees do not have to be posted on the ATM.
I am struggling with the verbiage for the notice. Does anyone have any suggestions? I have a meeting today about this topic and would appreciate your thoughts about issues I should address regarding this practice. Thanks so much!

I hope you get this in time for your meeting.

Posting an alert about fees is one of the "best practices" listed in the Interagency ODP Guidelines issued in February 2005. It's not a regulatory mandate, and you can only take care of your own machines as a matter of practice.

"ATM withdrawals may overdraw your account, and cause you to incur fees. Contact your bank for details." would seem to work fairly well.

I urge you to think through very carefully how balance inquiries from network ATMs will be handled. Although you may be able to give customers access to their ODP protection amount by approving network ATM withdrawal authorization requests, you definitely do not want an ATM you don't own to display the ODP-inflated balance. That would require you to make disclosures about your ODP fees and the time you give depositors to cure an OD on another bank's ATM, which is clearly not going to happen.

Thank you John. You were just in time! I like your suggested verbiage. If I understand how this is going to work, the balance will not be affected. The two balances provided at ATM's will be the customer's ledger balance (the balance as of last night's posting) as well as their available balance (last night's positng +/- memo posted transactions). Neither of the two balances will include the ODP amount.

Thanks so much for your thoughts.

Ours shows two balances:

Available without ODL
Available with ODL

Including a reference to an overdraft line of credit (where it's subject to Reg. Z and there is a commitment to pay ODs from the line) at an ATM doesn't trigger the disclosures required by section 230.11 of Regulation DD, so it's not a problem.