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#1619691 - 10/25/11 05:13 PM Opting In
NM Tiger Offline
Member
Joined: May 2004
Posts: 79
New Mexico
What incentive are you using to get customers to Opt in for overdraft fees.

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Operations Compliance
#1619863 - 10/25/11 07:41 PM Re: Opting In NM Tiger
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,960
Illinois
Be very, very, very, very, very careful about this concept. Shortly after Reg E was updated to include the opt-in, some creative marketing people got the idea of offering "perks" to customers that chose to opt-in. However, these "perks" will violate 205.17 (b)(3).

(3) Same account terms, conditions, and features. A financial institution shall provide to consumers who do not affirmatively consent to the institution’s overdraft service for ATM and one-time debit card transactions the same account terms, conditions, and features that it provides to consumers who affirmatively consent, except for the overdraft service for ATM and one-time debit card transactions.

If you decide that you want to give a toaster to everyone who opts in, you must give the exact same toaster to everyone who opts out.

The approach many banks use has to do with the concept of avoiding embarassment of a declined card, or needing medicine in the middle of the night and not having the funds, etc.

Personally, I'd rather be embarassed than pay an overdraft fee between $25-$35, and I wish (pipe dream) we'd teach our customers more about creating emergency funds to deal with emergencies than relying on expensive credit options.
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#1619958 - 10/25/11 09:30 PM Re: Opting In BrianC
NM Tiger Offline
Member
Joined: May 2004
Posts: 79
New Mexico
Thanks, we were not thinking of giving anything away. Just wondering what others were discussing with a customer that would make them want to opt-in.

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