Are there any federal regulations which prohibit debiting the deposit account without sufficient funds which is tied to the Overdraft Line of Credit (ODLOC) for the ODLOC payment owed?
We currently offer a loan, repayable in six monthly installments at zero percent interest, to help customers bring their checking account to a positive balance.
Letters are automatically generated and mailed to customers who may qualify for such loan once their account becomes 30 days overdrawn for $100 or more.
Upon receipt of the notification, the customer must call in as directed in the notification (or they can come into the branch) to request the fresh start loan. Their account will be reviewed. If the customer has previously had a fresh start loan with us, we will not make them another fresh start loan. In those situations where a customer requests a fresh start loan and we
are unable to make them one, would we owe the customer a Notice of Action Taken? Would Regulation B apply to these fresh start loans?
Does Reg O apply to overdrafts in an investment account?
If we increase an overdraft line of credit (unsecured) limit, what documentation do we need? Does the customer need to sign anything? Do we have to do a whole new loan or just document it in the file?
I have privilege pay and I've used it once already the other day. Can I use it again?
When we close an account due to overdraft, we mail notices to the customer of the amount owed and that the account should be brought to a positive balance to avoid any collection proceedings. Do we need to mail a notification to the account holder when we have sent the account to a collection agency?
Can you debit an auto loan for a debt owed on an overdrawn checking account or bad check if it is not specifically disclosed in the auto loan contract? This would increase the balance and interest that may be due on the original contract altering the agreement, correct?
For Reg. O compliance, is a Demand Clause required to be included in the Note for overdraft loans to executive officers?