Our Overdraft Disclosure lists ATM withdrawals and debit card purchases as types of transactions that can overdraw a customer's account. Because my bank is not participating in a Reg E Opt In/Out program, I've been advised to remove ATM withdrawals from the disclosure as a type of transaction that can overdraw the account.

Under limited circumstances, an ATM Withdrawal or One-time debit card transaction can overdraw an account, our bank simply will not charge an OD fee for that transaction.

I can't decide if i should make the revision as recommended or leave the disclosure as is.

We also decline NSF ATM/POS transactions. We updated our disclosure to let the customer know it is our practice to decline, but if an ATM/POS transaction should inadvertently overdraw their account, we will not assess an overdraft fee for that transaction.

I like the approach suggested by BetsyS. Note also the Regulation DD §230.4(b)(4) account disclosure requirement and Comment 230.4(b)(4)-5. If you have ATM transactions listed there, it should be removed, if you don't charge OD fees on ATM transactions.

Thanks for the help. I feel better about making the revisions.