Regulation E and ODP Manager

Consumers are required to opt in to include their ATM and everyday debit card transactions in Overdraft Privilege. Customers should be given the ODP Policy and A-9 Consent Form to opt in for Reg E at account opening but they may also opt in later. The four options to opt in for the ATM and everyday debit card coverage are: in person at a branch, over the phone, by mail, or electronically. Businesses are not required to opt in to have their ATM and everyday debit card transactions covered by Reg E.

For financial institutions that provide an account’s Reg E Opt In flag in the extract file, ODP Manager can determine if a consumer account has already opted in or has not yet responded with a Reg E election. If a customer has already opted in for Reg E coverage, their Welcome and Reinstatement letters will remind them that their Overdraft Privilege service includes coverage of ATM and everyday debit card transactions.  When a Welcome, Reinstatement, or Followup letter is mailed to accounts that have not yet opted in, these letters include the A-9 Consent Form to Overdraft Services and the information about opting in by mail, in person or over the phone, or electronically. By allowing customers the Reg E opt-in information when overdraft limits are assigned, when overdraft limits are reinstated, or annually in the Followup letter, ODP Manager may allow customers to have more opportunities to opt in for Reg E.

ODP Manager can also allow customers to submit their Reg E Opt-in election electronically. Strunk can create an online form that mirrors an institution’s A-9 form. This form would then be linked directly from an institution’s website. Email confirmations are generated when forms are submitted. The submissions are tracked in ODP Manager so that users can generate a list of accounts that need an updated Reg E election.

If you have any questions about Regulation E and ODP Manager, please contact Strunk Support at support@strunkaccess.com for more details.