Banker's Compliance Consulting Blog

Online Bankers Training - Overdrafts When No Regulation E Opt-In

Written by David Dickinson | Jul 30, 2019 1:41:31 PM

Question: 

Under Regulation E, if a customer doesn’t opt in and continues to have debit transactions that overdraw their account, what is the bank’s course of action with this customer?

 

 

Answer:

You could always consider revoking a customer’s ATM and/or debit card after reaching a certain number or dollar amount of overdrafts.  Keep in mind; however, that you cannot create different account terms and conditions based solely on whether a customer has opted in or not.  In other words, if a customer reaches an unacceptable number/dollar amount of overdrafts and you want to revoke the card, you need to treat opt-in and non-opt-in customers the same.

 

Join us for the Deposit Operations Webinar on August 27, 2019. We will answer all the questions submitted during the live webinar, in writing.

 

Register NOW!

 

Published
2019/07/30

 

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