Overdrafts When No Regulation E Opt-In

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.

 

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Published
2019/07/30

 

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