07/16/2023
An executive officer has a debit card transaction that has caused an overdraft. As to Reg O, we would pay and charge the fee. But as to Reg E he has opted out which means we would pay the item and not charge the fee.
I don't know which Reg takes precedence. The account is overdrawn less than $100.
02/12/2023
If a customer has a large deposited item returned on their checking account, can we legally advance on their HELOC if there is an
available balance, rather than have an overdrawn account?
05/22/2022
What department is best to manage employee account overdrafts?
01/31/2021
I understand the Joint Overdraft Guidance states that overdrawn accounts should be charged off after 60 days. Is there anything that would allow for an extension past the 60 day mark? (i.e. a fraud investigation, pending transactions, approval from upper management, etc.)
06/14/2020
How long do banks have to keep records of charged off checking and savings
accounts that are paid in full? How about if no amounts have been
collected?
06/07/2020
The opt-in requirements under 1005.17(b)(1) state that a bank "shall not assess a fee or charge on a consumer's account for paying an ATM or one-time card transaction."
Does the "one-time" term mean that we cannot charge a fee on the first transaction of two or more being paid and then we can charge a fee on the second when the consumer has not opted-in? For example, if a customer has not opted-in and an ATM causes an overdraft into the consumers account and then two EFTs are received and paid on the same day as the ATM for processing, can we charge or not an overdraft fee for any of the EFTs? On subsequent days, if the account is overdrawn by EFTs, can a fee for overdraft be charged?
04/28/2019
What are the requirements in relation to counseling reports for excessive overdrawn accounts and what regulation can I find that in? We already send notification out each time an account is overdrawn more than 6 times in a 12 month period. We also contact customers via phone and letters at 15, 30, and 45 days of being overdrawn. Are we required to mention "counseling?"
11/11/2018
I have a Reg E question concerning overdraft protection. If an account is not permitted to have our overdraft protection product (bounce protection) and a POS or ATM overdraws the account, are we allowed to charge the account an NSF fee? (This pertains to employee accounts, business accounts and our student checking accounts.)
09/16/2018
I have been setting up overdraft transfers for funds trying to pull from savings for ACH transactions. They have funds in their checking, and when I set it up and then repost occurs, the funds are transferred from checking along with a transfer fee. Do you know if I am breaking any rules? Normally I would be transferring funds manually. Or should we just be returning the items.
08/19/2018
We have a customer whose DDA is overdrawn. Today he made a request to do a wire transfer to be paid with cash. The transaction was completed. My question is after the fact and for future reference, could we have refused the wire transfer request until his DDA was no longer overdrawn?