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A-9 Needed for HSA Accounts?

Question: 
Do we need the A-9 form for HSA accounts? Our HSA accounts are housed on the deposit side and debit cards are issued. However, I know that we do not charge overdraft fees on these accounts, so I am thinking that the A-9 is not necessary? Is that right?
Answer: 

Answer by John Burnett:If you do not and will not charge these accounts any kind of overdraft fee, Section 205.17 of Regulation E won't be applicable at all, and you will not need an A-9 form.

Answer: 

Answer by Randy Carey:An HSA account cannot be overdrawn, as it would be a prohibited transaction, so any discussions regarding overdraft fees are a moot point.

First published on BankersOnline.com 10/25/10

First published on 10/25/2010

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