In a webinar on Reg E changes to overdraft, the presenter stated that if we comply early and start the opt in process, that we must also cease to charge fees on one time debit and ATM transactions. Is this correct?
We are a small community bank and do not have an overdraft protection program. Do we treat all our customers as opt-out come July 2010?
How are banks and servicers handling a consecutive overdraft fee? For example, if the account has been overdrawn for more than five consecutive days, the account will be charged a $10 overdraft fee on a daily basis until it goes positive. How will the bank/servicer manage the consecutive overdraft fee when the item creating or perpetuating the overdraft balance was an ATM withdrawal or one time debit card transaction on an account that did not opt-in?
When a business customer wants to view his accounts online and also make transfers, is there an agreement that needs to be signed stating which of his employees can have access to this capability? We do not know who of that business is making a transfer or inquiry, therefore we cannot monitor that activity. I would think that the bank is not liable and has no control. Is this correct?
In regards to the Reg E changes effective 7/1/2010, does the prohibition against charging fees on ATM or one time debit card transactions apply if you don't have any kind of courtesy overdraft program? For example, our bank does not authorize card transactions if there is no money in the account, however, at times checks or other transactions come in and pay out of the account before the card transaction posts, and since they have been authorized, we have to pay them. Will we be required to provide the opt-out notice?