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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David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transform the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM), and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have 3 adult children and 2 grandsons (none of whom live at home!) and 3 cats (of which Dave is allergic … the cats, not the children!). They live on a lake in Nebraska and when possible he can be found fishing or making sawdust in his shop. David plays the guitar & piano and enjoys singing with Karen. They occasionally lead worship at their church.