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Bombarded by Opt In/Opt Out

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Many bank marketers are being bombarded with information from various sources about Reg. E and the rules of Opt In/Opt Out. One of the areas of the greatest concern is, once the form is returned to the bank from an existing customer with the opt out option, how long do we have to honor that request? We are getting information now, that as long as we let him know, it will not be honored until August 15th, and we can continue to charge them an NSF charge until that time.

The Fed stated in the information that accompanied the final rule in the Federal Register, that the Fed Board expects that the bank would promptly discontinue the overdraft service for card transactions. Look at the fifteenth page of the FR document, left column, first complete paragraph. Whether or not your federal regulator's examiners will hold you to that standard is something else again.

First published on 3/01/10

First published on 03/01/2010

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