Overdraft Program Changed to New Program

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    Vicki Kramer

    Good morning. Our bank is replacing its overdraft protection product. The new product will have new eligibility requirements and overdraft amounts and will be more automated. A few questions, please. 1) Are we in compliance if we send out a letter to the current OD program participants advising that we’re ending the current product, replacing it with the new one, and provide a new disclosure for the new program participants? 2) Is the normal 30-day advance notice required? 3) What if the customer does not qualify for the new product? Adverse Action Notice, etc. needed? 4) Any other considerations? Thanks in advance for your help!

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