06/07/2010
Can we send the Overdraft Fee Notice in our monthly statements, and can we only send the notice to our existing customers with debit/ATM cards?
06/07/2010
We reviewed our overdraft charges originating from the ATM and one-time debit card transactions, and concluded that we will spend way more on notification, changes and explaining the opt-in for Reg E than we will lose in overdraft fees. Are we required to do anything if we are going to leave all our customers opted out? We won't charge for these transactions; we have already disclosed our fees correctly, so is any action required?
06/07/2010
As long as our system can support it, are we allowed to offer an opt-in (courtesy pay) on just debit transactions, but not ATM or PIN POS transactions? Our opt-in will be to a courtesy pay program which will allow the member's debit transaction to be authorized for up to $300 above their available limit. Can we set criteria to qualify for the courtesy pay, such as requiring the member to be current on all loans, be eighteen years of age or older, maintain a direct deposit of $100, bring negative balance current within a week, etc? Do we need to have a separate courtesy pay program for ATM/Debit transactions, or can we have one program, which covers all types of transactions, including checks, ACH, ATM, Debit, etc., as long as the member opts in for the courtesy pay for ATM/Debit transactions?
05/24/2010
We have received conflicting advice on whether we can require customers to opt-in to the Reg E overdraft fees in order to receive a debit card. Can we or can't we?
05/24/2010
With the new opt in requirements for Reg E, if a customer opts in, does that eliminate the need to inform the card holder that his ATM transaction will overdraw his account?
05/17/2010
Are we required to mail the Reg E Opt-in to existing customers if the bank chooses not to charge overdraft fees on the ATM or one-time debit card overdrafts? Is it mandatory?
05/03/2010
With Reg. E, if you opt out and then want to opt in, can you? If you opt in can you later opt out, can you?
05/03/2010
If it will not be our practice to charge an overdraft fee for a POS transaction or ATM withdrawal, are we required to notify our customers of the opt-in/opt-out choice?
04/05/2010
Please explain (preferably in simple terms) what the switch means in reference to the routing of ATM transactions.
04/05/2010
I know that if a customer loses his ATM card and has the PIN written on it we can’t hold that against him, but can we deny a claim if he loans the card to a family member for a one-time transaction and the family member goes overboard with multiple unauthorized transactions?