Answer:
Look at the transactions that created the current overdraft. If they are all ATM/one-time debit card transactions, you can't impose any overdraft fee, including a continuing overdraft fee. If, however, one or more of the offending transactions is not an ATM or one-time debit card transaction, pick the earliest of those transactions not covered by Section 205.17 of Regulation E, and start counting from its posting date. See Supplement I to Regulation E, Comment 17(b)-9.
First published on BankersOnline.com 9/27/10
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