Reg E overdraft opt-ins

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Question:

We do not approve overdrafts unless a customer has a line of credit or ties a savings account to the checking. Should we be obtaining an opt-in so we can charge a fee if the customer does not have available funds in the line of credit or savings account?

Answer:

The opt-in requirement in Reg E is only for institutions that offer an automated “courtesy pay” overdraft program where overdrafts are approved against a “padded” balance. You should not obtain an opt-in if you do not offer such a program since the only thing a customer can opt into is a fee.

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