Overdrafts & Regulation E Opt-In Issues

If you allow customers to opt-in so that you can charge them overdraft fees for one-time debit card and ATM transactions, that is a benefit for your bank. If you get this benefit, then the customer should also get a benefit. Typically, we see that being an overdraft cushion of funds. If the customer doesn’t receive any benefit from opting in, you have not only Regulation E issues but potentially UDAAP as well.

Jerod explains more in the video.


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Video Highlights:

  • A Regulation E Opt-In should provide a benefit to the customer, such as a cushion of funds.
  • Customers must be given the option to opt in for one-time debit and ATM transactions separately from other overdraft protection programs.
  • Delayed benefits are not allowed; customers must receive their benefit at the same time that a bank receives theirs.

Published
2023/07/18
Jerod Moyer

Jerod Moyer

Jerod is the leader of Banker’s Compliance Consulting’s training productions. He is a nationally recognized speaker. Whether it’s a conference, seminar, school, webinar or luncheon, it’s easy to stay engaged when he presents due to the amount of passion and energy he brings to each and every compliance topic. Jerod has spoken on behalf of the American Bankers’ Association, BankersOnline, many state banking associations, private compliance groups and financial institutions. He is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru. Jerod likes to spend his time (between reading regulations and producing compliance training!) relaxing at the lake with his wife and three children, following their activities or engaged in something sports-related!

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