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Obtaining Reg E Opt In Decisions is Essential, but Financial Institutions Must do it Properly

Posted by Jeff Harper, President, BSG Financial Group on Nov 6, 2017 10:24:32 AM

 

Since the 2010 Amendment to Regulation E (Reg E), banks that want to offer and charge for overdraft coverage on ATM or one-time debit card transactions have been required to obtain affirmative consent from customers before charging an overdraft fee for extending overdraft coverage for these transactions. Many consumers have realized the benefits of opting into overdraft coverage when using their debit card, including avoiding embarrassment at POS and obtaining goods and services, like gas and groceries, at the time they need them.

However, a large percentage of customers—as many as 80% according to the Consumer Financial Protection Bureau (CFPB)—have not opted in (and/or made a decision about opting in) to their institution’s overdraft coverage for debit card transactions. For safety and soundness purposes, most institutions do not provide an overdraft limit for card channel transactions on accounts without a Reg E opt in decision. This results in a denied transaction whenever a customer attempts to access more than their available balance. It can be very frustrating for a consumer, especially a new customer, to have a POS transaction denied when attempting to use a debit card. The consumer receives no immediate feedback informing them that the transaction was denied due to insufficient funds because they didn’t opt-in to Reg E.

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Topics: Courtesy Overdraft, Debit Denials, Overdraft Compliance, Reg E