Now that July 1 has come and gone, it’s likely institutions have made significant decisions in reaction to the Federal Reserve’s requirement that consumers must opt in to overdraft protection for one-time debit card and ATM transactions. As compliance officers and management teams know well, a decision had to be made by July 1, 2010, regarding whether to ask new customers to opt in to overdraft fees for card transactions or to forgo what to many represents significant fee income. Institutions still have until August 15 to acquire affirmative/opt-in decisions or stop charging overdraft fees on card transactions for current customers. Some institutions have chosen to wait and see how things play out after the mandatory compliance dates have passed to determine a course of action with regard to obtaining opt-ins or forgoing overdraft fee income.
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