Delayed courtesy pay access for new accounts

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Question:

We have a 30-day waiting requirement before a new customer gets a courtesy pay limit, but we do try to capture the opt-in response at account opening. Is that considered delaying the benefit? We would not charge any OD fees if there is no overdraft coverage, and there would not be coverage if there is no courtesy pay limit.

Answer:

If I opt in prior to receiving the cushion, or benefit, you should not charge me for ATM or one-time debit transactions until I receive that benefit. So, if you’re delaying the benefit, you should be okay if you’re also delaying the charge.
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