There may already be a post out there somewhere on this but I wanted to get this FYI out there.

On a conference call with the FDIC in the KC region yesterday they discussed how they are focussing on unfair and decptive practices, particularly related to overdraft protection.

The one item I thought was interesting is that if you offer an overdraft line of credit and include this line of credit in the balance the cusotmer sees at an ATM, on-line banking, or phone banking you need need to do a few things:

1) You need to include a statement in the initial disclosure you provide to the customer that clearly indicates what is all included in the balances you disclose to the customer.

2) You need to provide some form of a notice at your ATMs that alerts customers to the fact that their balance may include their overdraft line of credit.

I guess the notice at the ATM can be general (like a sticker). The reason for the disclosures is because the customer may incur interest charges should they access their ready reserve via an ATM withdrawal.

Of course if you don't include this overdraft line of credit balance or disclose two balances to the customer, you might be okay. But something to think about!

At my previous institution it was decided to not include ODP in teh balance at the ATMs...it was way easier than posting notices.