Our bank offers $500.00 automated overdraft privilege to all customers' checking accounts who qualify with the exception of business and minor accounts; however, we do have certain criteria that must be met such as a $300.00 average balance, account must be open 30 days, no levies or garnishments, no delinquencies on loans, limited to one account per social security number. We also have a Security Club 55 account in which we charge a $4.50 monthly service charge fee, an advantage checking account in which there is not a monthly service charge fee, and a Security Club account in which we charge a $7.50 monthly service charge fee. Are we in violation of Reg B according to the overdraft guidance that has been released?

That is a really difficult call to make. You'd have to line up each type of account to which ODP can be linked, and compare them all. If the Security Club 55 account is a "better deal" for someone solely because he or she is 55 years old or older, you MIGHT have a problem.

The fact that you have an "advantage checking" account makes this hard for an outsider to weigh pros and cons. That account gets no monthly service charge. How does it stack up against the Security Club 55 account on activity charges (if any), interest paid (if any), etc.?