Compliance Challenge: Can CUs give overdraft incentives?

WASHINGTON (3/9/10)--In this month's Compliance Challenge, the Credit Union National Association (CUNA) addresses a question regarding overdraft protection policies.

In the Challenge, a credit union asks whether or not it can provide incentives such as gift cards to members that choose to opt in to its overdraft service for ATM and one-time debit card transactions.

According to CUNA, while credit unions may offer incentives to members that opt-in to the overdraft service for ATM and one-time debit card transactions, the same incentive would also need to be extended to members that do not opt in to the overdraft program.

Additionally, credit unions and other institutions may offer incentives to members or customers that enroll in overdraft services for check and ACH transactions, as these transactions are not covered by Regulation E overdraft rules.

Regulation E also requires credit unions and other financial institutions to apply the same account terms, conditions, and features to all members or customers, regardless of their opt-in choice, and this rule would also apply in cases of debit card abuse. In the example provided in the Compliance Challenge, CUNA said that a credit union can only suspend the debit card of a member that has not opted in to its overdraft program, but violates its stated overdraft account rules, if that rule also applies to members or customers that have opted in to the overdraft program.

To see the full Compliance Challenge, use the resource link.

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