Do all banks need to send out the opt-in/opt-out forms if they do not plan on charging any fees on those types of overdrafts?
We reviewed our overdraft charges originating from the ATM and one-time debit card transactions, and concluded that we will spend way more on notification, changes and explaining the opt-in for Reg E than we will lose in overdraft fees. Are we required to do anything if we are going to leave all our customers opted out? We won't charge for these transactions; we have already disclosed our fees correctly, so is any action required?
We have received conflicting advice on whether we can require customers to opt-in to the Reg E overdraft fees in order to receive a debit card. Can we or can't we?
Must a bank send the opt-in notice to all of its customers, or may it send it to particular categories of customers, for example, only those customers that have used overdraft service in the past?
Are we required to mail the Reg E Opt-in to existing customers if the bank chooses not to charge overdraft fees on the ATM or one-time debit card overdrafts? Is it mandatory?
With the final rule on overdraft fees, do you suggest we change only the Reg E policy or our overdraft policy (very generic) or both?
With Reg. E, if you opt out and then want to opt in, can you? If you opt in can you later opt out, can you?
Concerning Reg. E and opt-in, should authorized signers, rather than an account owner, on an account be allowed to make the opt-in decision?
Why should customers opt into overdraft protection under Reg E?
Regarding Reg E and overdraft charges, currently our bank has a five day continuous overdraft charge. If someone is overdrawn five consecutive days, then we charge $15. If a one time debit or ATM charge causes the customer to be overdrawn, and he has chosen to opt-out, can we still charge the five day overdraft charge?