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Reg E Opt-in Confusion

Answered by: 
David A. Dickinson

Question: 
If a customer at a bank has the overdraft service, and has chosen to opt-out, we cannot charge, but if he chooses to opt-in, then we can. Is that correct? What if the customer doesn't have the overdraft service with us on his checking account? Can we charge with no overdraft service if he opts out? Can we charge with no overdraft service if he opts in?
Answer: 

If the customer doesn't opt-in, you cannot charge for any NSF/OD fees incurred from ATM or one time debit card transactions. The customer doesn't have to choose to opt-out, just not opt-in.

An OD service includes all OD's, not just LOC or overdraft privilege programs. If the customer opts-in, you can process the OD and charge him/her.

First published on BankersOnline.com 9/13/10

First published on 09/13/2010

Filed under: 
Technology
Filed under technology as: 
ATM
Fees

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