Regulation E: Opt-in Procedures

Overview

Opt-In/Opt-out Overview

Regulation E (Reg. E) requires consumer clients to opt-in to the provision that allows their one-time (non-recurring) consumer debit card transactions to be covered by Bounce Protection.

If a consumer client chooses to opt-in, the debit card authorizes one-time transactions within the account's overdraft limit.

If a consumer client dos not opt-in, one-time transactions made with the debit card will decline if sufficient funds are unavailable in the account.

Reg. E Opt-in applies only to consumer checking account clients with a consumer debit card. Consumer clients can change their Reg. E choice as desired. Associates do not have the authority to change the client’s Reg. E choice without the client’s consent.

 
 

New Client

New Client: Opt-in/Opt-out

  1. Explain the value of opting in with the client during new account opening.
  2. Record the consumer client’s Reg. E choice in Streamline.
    A = Accept
    D = Decline
  3. Provide the client with the Reg. E forms printed with the new account documents.
    • Opt-in forms: Give the client the below forms when they have opted in:
      • What You Need to Know about Overdrafts and Overdraft Fees (Acceptance)
      • Confirmation of Consent
    • Opt-out form: Give the client the below form when they have opted out:
      • What You Need to Know about Overdrafts and Overdraft Fees (Declined).
 
 

Existing Client - In Person

Existing Client - Updating Reg. E Choice

  1. Verify the client's identity.
  2. View code listed on each consumer account to determine if a Reg. E choice has been made: Account Inquiry > Insufficient Funds - Card Opt-In Status
    • = Accept opt-in  
      • The client accepted the conditions of the overdraft protection service for card transactions.  
      • Overdraft fees are charged on ATM and POS transactions.
    •  = Declined  
      • The client declined the overdraft service for card transactions.  
      • ATM and POS transactions will not be authorized within the overdraft limit associated with the account.
    • =  Exempt/Non-consumer  
      • This is a non-consumer business account.
      • Business accounts are exempt from Reg. E.
      • Business debit cards are set to be able to use the overdraft protection service for card transactions.
    • = Failed to respond  
      • The account owner has not opted-in to the overdraft service. 
      • ATM and POS transactions that would cause an overdraft will be declined.
    • = Revoked authorization  
      • The consumer client revoked the previous opt-in choice. 
      • ATM and POS transactions that would cause overdrafts will be declined.
  3.  Print the Reg E Opt-In Disclosure form and have the client read and complete the form including: 
    • Client name
    • Opt In/Opt Out preference
    • Account information the decision applies to
  4. Update the Reg. E choice by completing the following Synapsys Service Event:
    • Opt-in -- Synapsys > Reg E > Reg E Opt-in
    • Opt-out -- Synapsys > Reg E > Reg E Opt-out
  5. Provide the client with a copy of the form.
  6. Scan the form and include with your daily work.
  7. Reg E updates take effect in 1-2 business days.
 
 

Existing Client - Called In Request

Clients that are calling in to change their Reg. E opt in/out status can be directed to call the Client Service Center (888.671.0400) or they can Chat with an associate by logging into their bank online or visiting our website.  Our direct bankers and chat associates will verbally disclose to the clients on our recorded lines.

 
 

 

 

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