Responding to a statutorily required review of the CFPB’s 2009 overdraft rule today, the American Bankers Association noted in a comment letter that the “opt-in” rule has empowered customers to make informed choices about seeking or declining overdraft protection services for debit card point-of-sale or ATM transactions. ABA recommended that the bureau not make any changes to the rule.
ABA referenced survey data produced by the association and an ABA-sponsored research paper that demonstrate that frequent users of overdraft are well aware of the fees they incur to use the product, the monthly and year-to-date fee information that is provided on their bank statements, and their right to opt out of overdraft protection at any time.
In addition, ABA noted that banks provide an increasing number of ways for customers to limit or avoid overdraft fees through sending low-balance alerts, linking customers’ accounts, and imposing de minimis thresholds and caps on total fees that may be charged per day.