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ODP Discussed at New Account Opening

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Question: 
At a new account opening, if overdraft protection is discussed is that considered promoting overdraft protection? We do not have any written advertisements and/or disclosures discussing overdraft protection, we only mention it at account openings.
Answer: 

In person discussions with a consumer are specifically included in the list of communications that do not trigger the statement disclosure requirements of section 230.11(a) -- see 230.11(a)(2)(iii) -- or the advertising disclosure requirements of section 230.11(b) -- see 230.11(b)(2)(vi) -- of Regulation DD.

First published on BankersOnline.com 03/05/07

First published on 03/05/2007

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