Question: We currently have a daily limit on the number of overdrafts we charge but are going to begin charging for each overdraft occurrence, regardless of the number. How do you feel regulators will look at this practice and what should we tell management?
Answer: First off, unless you had an opt-in under Regulation E for ATM and one-time debit card transactions, you can’t just begin charging for them. So, you will want to ensure your system is set up correctly as to what you can and cannot charge for. Your management will likely need to be prepared to answer questions on why the limit was removed and have information ready on how the change has impacted your customers.
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