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#2028228 - 07/20/15 05:44 PM Advertising Overdrafts
cowgirlsrule Offline
100 Club
Joined: Jul 2014
Posts: 194
Arkansas
We have a checking account that we want to do an advertisement in newspaper. Following is listed $3 monthly fee waived if enrolled in free e-statements** (verbiage for checks is at bottom of advertisement) Free online* banking & e-statements** (with verbiage on internet service provider fees may apply
15 free Billpays per calendar bank anytime/anywhere with free mobile app** Visa Debit card available

My question is we have "Overdraft privilege added to qualifying accounts - does that statement trigger the disclosures for overdraft. We are not advertising as a "Free" account.

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Operations Compliance
#2028272 - 07/20/15 07:31 PM Re: Advertising Overdrafts cowgirlsrule
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The mere mention of "overdraft privilege" will trigger the requirements of Regulation DD section 1030.11(b) unless one of the exceptions in 1030.11(b)(2), (3) or (4) applies.
Last edited by John Burnett; 07/20/15 07:32 PM.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#2028303 - 07/20/15 08:54 PM Re: Advertising Overdrafts cowgirlsrule
cowgirlsrule Offline
100 Club
Joined: Jul 2014
Posts: 194
Arkansas
Okay. I had our marketing department add the information but wanted to make sure I was correct. Thanks.

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