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#1423877 - 08/04/10 01:33 PM ATM Overdraft Disclosures
Random Offline
Gold Star
Joined: Jun 2008
Posts: 287
Are there any new requirements for notifying a customer that has opted-in and makes an ATM withdrawal that a transaction is over-the-limit of available funds and will overdraw the account? I know there is the 2005 overdraft guidance, but I am just trying to make sure that the rules do not address this issue as well. Thanks!

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Operations Compliance
#1423967 - 08/04/10 02:37 PM Re: ATM Overdraft Disclosures Random
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,722
Illinois
The disclosure requirements are set forth by the change to Reg DD that went into effect in January.

(c) Disclosure of account balances. If an institution discloses balance information to a consumer through an automated system, the balance may not include additional amounts that the institution may provide to cover an item when there are insufficient or unavailable funds in the consumer’s account, whether under a service provided in its discretion, a service subject to the Board’s Regulation Z (12 CFR part 226), or a service to transfer funds from another account of the consumer. The institution may, at its option, disclose additional account balances that include such additional amounts, if the institution prominently states that any such balance includes such additional amounts and, if applicable, that additional amounts are not available for all transactions.

In layman's terms, if you disclose a balance at an ATM that includes the overdraft privledge the customer opted into, you are then also required to disclose your overdraft policy, fees that will be charged, etc. Since you obviosuly cannot disclose your policy on every ATM in the world, this essentially prohibits you from doing so. You can still approve withdrawals against the overdraft coverage, but the customer's receipt should show a negative balance when the transaction is completed.
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