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?
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.
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