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Overdraft Fee at ATM

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With the new opt in requirements for Reg E, if a customer opts in, does that eliminate the need to inform the card holder that his ATM transaction will overdraw his account?

No, that requirement is one of the Best Practices listed in the inter-agency ODP Guidance document from 2005. The Fed recently said that it still considers the Guidance document valid, to the extent it hasn't be superseded by subsequent regulations, and recent OTS action imposing a Cease and Desist Order and Civil Money Penalty order on a bank for playing fast and loose with an overdraft program should drive home the fact that regulators continue to take those Best Practice seriously.

First published on 5/24/10

First published on 05/24/2010

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