Overdraft privileges are not available in certain circumstances (such as for savings or certain account types, abuse, etc.) It is disclosed that this is the case at account opening. Well of course our customers have rooted out a way in our platforms to opt-in for privileges. This is a persnickety issue to resolve so the current practice is that these are caught in a report and we can reject that attempt to opt-in. What is now being proposed is that since the customer is given the impression of opting-in, we should send a notice reminding them that they are not eligible. There is not an explicit requirement to do so and this seems to be a can of worms to consider. Thoughts? Pros/Cons?

If you're using the standard language, your Opt-In should have language pointing out the overdrafts are at the discretion of the FI. It was very rare in my experience to have a member raise this issue. However, it has happened. But every time its has, I've pointed out to them that the the Opt-In authorizes the FI to expand coverage to ATM and one-time debit card transactions when and if they qualify for overdraft protection and nothing more.