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#1692222 - 04/24/12 09:00 PM Debit Card POS & ACH
DepositOps Offline
Member
Joined: Mar 2005
Posts: 75
There are a few stores (like Target) that are now offering a debit card which is tied to your account at a bank. The transactions post to the account as an ACH item, but specifies in the description that it is the Target debit card POS transaction. Since it is not a POS transaction to me, do the overdraft rules apply as far as charging NSF fees?

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Deposits and Payments
#1692238 - 04/24/12 09:21 PM Re: Debit Card POS & ACH DepositOps
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,972
Illinois
You do not need to worry about customer opt-in opt-outs and charging fees. If you are presented with an ACH debit for a decoupled debit card, you are free to charge a fee, pay the item, return the item, etc. regarding of the opt-in status oof the account.
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#1692284 - 04/25/12 12:33 PM Re: Debit Card POS & ACH DepositOps
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
You'll find the "carve-out" for decoupled cards in Comment 17(b)-1.i.:

1. Scope. i. Account-holding institutions. Section 1005.17(b) applies to ATM and one-time debit card transactions made with a debit card issued by or on behalf of the account-holding institution. Section 1005.17(b) does not apply to ATM and one-time debit card transactions made with a debit card issued by or through a third party unless the debit card is issued on behalf of the account-holding institution.
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