Revision to Reg V - Model Notices

Are we to give the negative information notice just approved under Regulation V to overdrawn DDA accounts if we report to agencies such as CheckSystems? The definition of "credit" under ECOA indicates to me that it includes any debt - loans as well as overdrawn accounts. I'm assuming that CheckSystems is considered a "nationwide consumer reporting agency".

yes for your reasons stated.

Yes. Your conclusions are correct.

When it becomes effective...right?

I believe the mandatory date is 12-4-04.