For those CU's that use Symitar and use the "Reg E Member Communication" Tracking Record solution that Symitar provided for the Reg E Opt In requirements for ATM and nonrecurring Debit transactions back in 2010, Please continue reading.We use the Symitar provided tracking record to code a member's election to have their ATM and nonrecurring debit transactions paid. The tracking record is coded either when the account is opened, or at a later time if the member calls or opts in online. Note however, that a member is not immediately eligible for our overdraft program just because they have opted in. They must wait 30 days from account opening, and make a cumulative $200 deposit into their account before we grant them any overdraft coverage. The problem we have is with debit transactions where the amount authorized is much lower than the settlement posted to the account, and the account is drawn negative (i.e. a gas pump authorization for $1, but the member pumps in $50 in gas). In these cases, our system will assess an overdraft fee to the account if the member has opted in, even though technically, the member is not yet eligible for our overdraft program. My IT Department tells me that this is a core Symitar program that assesses this fee. I see two potential issues to this. 1) the member may beleive that they have overdraft coverage, when if fact they do not, and subsequent transactions will be declined until they bring their account current, and 2) other members who have not opted in to the Reg E overdraft program will have their transaction paid in the same circumstances, but will not be charged a fee. Accordingly, I see this as a potential UDAAP issue, and am advising my Operations area to do something about this.Are any other Symitar CU's experiencing this issue wtih Reg. E Debit Transactions? If you are, I would love to hear how your CU has addressed this issue. Thanks. Doug Wright
January 21, 2013 - 5:28pm
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