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Reg O and Fee Waivers

Question: 
Is it a Reg O violation to waive an automatic savings/deposit account transfer fee to cover an overdraft for an insider?
Answer: 

Answer by Jim Bedsole: If there is an automatic transfer program in place that covers the NSF amount, then no overdraft occurs. If no overdraft occurs, it doesn't matter about whether a fee is charged or waived for the automatic transfer.

Answer: 

Answer by Dan Persfull: It appears they have a transfer fee for this account type set-up therefore they can't give the insider preferential treatment over other customers who may have this same set up so I would have to opine they cannot waive the fee based on my understanding of the question.

First published on BankersOnline.com 3/28/11

First published on 03/28/2011

Filed under: 
Filed under compliance as: 

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