Posted by Anthony Demangone
When working to comply with NCUA's Truth in Savings regulation regarding overdraft protection programs, don't forget about the changes concerning how you disclose balances. In short, if you disclose balances to a member through an "automated system," the balance cannot include any additional ODP-related balance that could be used to clear the item. You "may," if you wish, disclose such additional ODP-related balance if you prominently state that any such amount includes such additional ODP amounts, and, if applicable, that such amounts are not available for all transactions.
So, what are "automated systems?" They would include any automated system through which a member can request an account balance, such as online banking, telephone-based systems, and ATMs.
Want some homework? I'd check to see where you disclose automated balances to see if you need to make any changes.
HUD really took this one to the wire. They finally updated their RESPA settlement cost booklet roughly 2 weeks before it's use becomes mandatory. Happy printing.