Overdraft Protection Reg. DD/ Reg. O??? | For Bankers. From Bankers

Skip to content

BOL Conferences

BankersOnline.com Forums Banker Forums Deposits and Payments Overdraft Protection Reg. DD/ Reg. O???

Thread Options

#544301 - 05/05/06 08:31 PM Overdraft Protection Reg. DD/ Reg. O???
J2C Diamond Poster Joined: May 2004 Posts: 1,475 Big Brother knows and that's a...	Hi all. We are going to be rolling out our ODP program in the next few months. Being that this program does not fall under reg. Z, does anyone know of any implications this may have for reg. O? For those of you that currently have this type of program in place, do you offer it to employees, officers, directors? If not, why? Thanks so much and have a great weekend! _________________________ My opinion is mine only- not my employer's!
Return to Top

Deposits and Payments

#544302 - 05/05/06 08:52 PM Re: Overdraft Protection Reg. DD/ Reg. O???
John Burnett 10K Club Joined: Oct 2000 Posts: 40,086 Cape Cod	Regardless of whether an overdraft is subject to Regulation Z, it is still an overdraft. Regulation O doesn't care what you call it. Several banks have decided not to allow courtesy overdraft services for directors or officers who are subject to Reg. O, for this very reason. _________________________ John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
Return to Top

#544303 - 05/07/06 01:45 PM Re: Overdraft Protection Reg. DD/ Reg. O???
Elwood P. Dowd 10K Club Joined: Aug 2001 Posts: 21,939 Next to Harvey	...and some banks ease their administration of overdraft services a little further by not considering directors or any employees as eligible to participate. Yes, it's a double standard, but the ability to rationalize frequent overdrafts as responsible financial behavior has its limits. _________________________ In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
Return to Top

#544304 - 05/08/06 01:02 PM Re: Overdraft Protection Reg. DD/ Reg. O???
J2C Diamond Poster Joined: May 2004 Posts: 1,475 Big Brother knows and that's a...	Quote: Regardless of whether an overdraft is subject to Regulation Z, it is still an overdraft. Regulation O doesn't care what you call it. Several banks have decided not to allow courtesy overdraft services for directors or officers who are subject to Reg. O, for this very reason. Thanks John, this is exactly what I thought. Quote: ...and some banks ease their administration of overdraft services a little further by not considering directors or any employees as eligible to participate. Yes, it's a double standard, but the ability to rationalize frequent overdrafts as responsible financial behavior has its limits. This is where we are hitting a wall. Do we offer it to employees or not? Currently many of the employees have an overdraft line, but if we eliminate that product we need to decide what to do. I do agree, allowing overdrafts for employees is kinda hypocritical. _________________________ My opinion is mine only- not my employer's!
Return to Top

#544305 - 05/08/06 07:16 PM Re: Overdraft Protection Reg. DD/ Reg. O???
golffan Junior Member Joined: May 2003 Posts: 32	Am I correct, the welcome letter as she described is an "advertsiment" and would be subject to the YTD $ being disclosed on the statements??
Return to Top

#544306 - 05/08/06 07:21 PM Re: Overdraft Protection Reg. DD/ Reg. O???
John Burnett 10K Club Joined: Oct 2000 Posts: 40,086 Cape Cod	Yes. The "welcome letter" constitutes an advertisement under the revised definition of advertisement in Regulation DD (as of July 1, 2006). _________________________ John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
Return to Top

Previous Thread

Previous Thread

View All Threads

Next Thread

Hop To

Moderator: John Burnett