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No overdraft service, no opt-in

Question: 
Can our bank obtain a Reg E opt-in for overdraft fees to allow us to charge our customer when a debit card transaction overdraws his account because a check or ACH posted before the debit card purchase transaction?
Answer: 

If the bank doesn’t actually provide overdraft services for ATM and one-time debit card transactions, it cannot accept an opt-in for the purpose of being able to charge OD fees when a debit card transaction overdrafts an account when it was authorized but intervening transactions have “used up” the account balance before the debit card transaction posts.
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Learn more about John Burnett’s webinar
Overdrafts – A Current View

First published on 11/18/2018

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