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October 24, 2016

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Steve Van Beek

Ah - Reg D!! The links to my Reg D blog posts from 2012 were a blast from the past! As the CFPB works toward an overdraft rulemaking, the questions about Linked Accounts and Reg D are still very important. What if a CU promoted the Linked Accounts (as the CFPB would like) but did not clearly and conspicuously disclose the Reg D limitations? Would the CFPB (or NCUA) view that as deceptive?

See you in NOLA!

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