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Opt-out of overdrafts by check, ACH, etc.

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Question: 
When the new Regulation E amendment becomes effective that prohibits opt-out programs for overdraft services for ATM and one-time debit card transactions, will we have to change our opt-out program for other types of overdrafts?
Answer: 

No, you can continue to offer an opt-out of overdraft services covering ACH, check and other transactions, as long as you offer an opt-in program covering overdraft services for ATM and one-time debit card transactions. You won't be permitted to link the two overdraft services together so that to get coverage of checks, ACH, etc., the consumer has to opt into coverage for ATM and one-time debit card transactions.

First published on BankersOnline.com 1/04/10

First published on 01/04/2010

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