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Revoked overdraft program means revoked opt-in

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Question: 
If we determine that our customer is abusing the overdraft program and we revoke their access, but later reinstate, do we need to obtain another opt-in for Reg E?
Answer: 

The customer cannot opt into a service you are not providing. If you terminate the customer’s access to your courtesy overdraft program, then their previous opt-in is also terminated, and you cannot charge overdraft fees for one-time ATM/Debit card transactions when you are not providing the service. If the program is reinstated, the customer should provide a new opt-in at that time if they want the ability to overdraw their account using their debit card.

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Learn more about Brian Crow’s webinar The Maze of Overdraft Compliance

First published on 10/11/2020

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