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#1429412 - 08/16/10 01:53 PM Prohibited from charging Uncollected Funds Fee?
AuditorK Offline
Platinum Poster
Joined: Feb 2003
Posts: 962
PA
We are not offering customers the ability to opt-in to having ATM/one-time debit card transactions paid when there are insufficient funds. I know we can't charge OD fees beginning today, but...

Is the bank also prohibited from charging a fee for ATM/one-time debit card transaction posting against uncollected funds? I can't find mention of this in the new Reg E changes.

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Operations Compliance
#1429449 - 08/16/10 02:30 PM Re: Prohibited from charging Uncollected Funds Fee? AuditorK
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
As is almost always the case, when you can't find something, go back to the definitions. Here's the key piece of the definition of "overdraft service" under §205.17(a):
Quote:
For purposes of this section, the term “overdraft service” means a service under which a financial institution assesses a fee or charge on a consumer’s account held by the institution for paying a transaction (including a check or other item) when the consumer has insufficient or unavailable funds in the account.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1429458 - 08/16/10 02:39 PM Re: Prohibited from charging Uncollected Funds Fee? John Burnett
AuditorK Offline
Platinum Poster
Joined: Feb 2003
Posts: 962
PA
Thank you very much John. Never thought to go back to the definitions. Lesson learned! wink

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