In many cases, the reason an opted-out member receives the non-return fee is because this transaction is a recurring payment. Recurring transactions are not covered by the Reg. E Opt In/Out requirements. You can identify this by the * after the DBT/WDR trans description on the member's transaction history. Recurring transactions are posted and fee'd even if the member is Opted Out.

The system recognizes a blank in the Reg. E Opt In/Out field on the member's MASTER record as the same as Opted In for overdraft services, not Opted Out. Since CU*BASE membership maintenance programs will not allow you to leave this field blank, this generally only happens in cases where a flood routine is done to adjust multiple membership records on your MASTER file, such as in a new client conversion or special job request.

Tool # 518 Members Reg. E Opted In/Out/Undecided is a canned Query that will split your membership by those opted In, then opted out, and finally those undecided. Any maintenance performed on the new Opt In/Opt Out flags that are within the membership and sub accounts write out to file MASTRL in FILExx, which can be queried to monitor for activity. We suggest monitoring this daily. Select Records of MTANROPT (Reg E Opt In/Out Flag) equal to ‘I’, and MTANROPTDT (Reg E Opt In/Out E  More...

Think of it this way: the member might have a negative balance limit, but Reg. E says you aren’t allowed to charge them a fee for dipping into it unless they specifically opt in for that level of service. But this rule of thumb ONLY applies to ATM and everyday debit card transactions, NOT to checks and ACH items, nor to recurring debit transactions. Since debit card transactions that have been authorized and come through to CBX for posting cannot be returned like a check or ACH item, when  More...

This might be the case if the membership designation for the membership is set to be Exempt from Reg E. opt in/opt out requirements. Learn more about how to change the opt in/out setting in the Managing Your Opt In/Opt Out (Reg E) Offering booklet linked to below.

Credit Union ABC has activated the Reg E opt in/opt out feature and has configured a NSF fee. John Smith, a member of ABC Credit Union, has elected to opt out of receiving overdraft services. John will not be charged an NSF fee on one-time PIN ATM Debit (13) and Debit Signature (16) transactions. John will be charged an NSF fee on any recurring PIN ATM Debit (13) and Debit Signature (16) transactions, which are not covered by the member's Reg E opt in/opt out setting.

The settings that control how this works are part of Tool #558 NSF/Overdraft Transfer Configuration , on the Overdraft Protection Activation screen. There are two flags for ANR/courtesy pay: Use Negative Balance Limits for Authorizations and Use Negative Balance Limits for Posting . They control whether the member's ANR limit is added when determining the available balance amount. There are four different combinations of these flags: Authorization Flag Posting Flag Description of Result  More...

In this particular member's situation there was no activity in either October or November that triggered a statement. The credit union's quarterly (and year-end) statements are configured to produce a statement for every member, regardless of activity level, but monthly statements are more restrictive in an attempt to save postage costs, and not every member gets a statement every month. NOTE: CU*BASE statements have a considerable number of configuration options that allow credit unio  More...

Our understanding is that this is strictly forbidden under the regulation; you must give members the choice and cannot discriminate based on the choice they make. Remember that ANR isn’t just for Debit cards. Changing a member's Negative Balance Limit would affect checks and ACH items as well. The Reg. E Opt in requirement is only for ATM and one-time debit transactions. You really cannot tie your overall Courtesy Pay program to this Opt In flag.

The most likely reason is that the member did not have any activity for the month that would trigger a statement, based on the CU's configuration. Most credit unions have their statement configuration set up to print a monthly statement only if the member has a checking account, and only if there is activity on that account, saving postage costs on months when there is no activity. You can verify this by viewing his Share Draft Transaction Inquiry in Phone Operator, then compare that to yo  More...

Online CUs must contact a Client Service Representative to make these changes to your configuration. (You can, however, view the configuration using Tool #961 View Reg E Triggers for Statements .) As long as you let us know before the last day of a month, we can make the changes to your configuration before statements are generated on the 1st. (Self Processors can change these settings via OPER Tool #5434 Member Statement Config .) Regulation Z Reg. Z

Well, it's a little of both, actually. If you activate something that’s optional in CU*BASE but there is not a corresponding link to that from somewhere in your master navigation, then members won’t be able to get to it. As an example, take the overdraft services feature, where members can change their Reg E opt in/out choice online. If you do not have a link to this in online banking from either the mega menu, on a clickable ad, or on a widget bar, then even if you activate i  More...

One reason might be that the items were posted but no fee was charged. The most common reason would be a member who was opted out from Reg E services, so that when the item was presented we force-posted it but could not assess a fee. The other reason could be an item that fell within your configured no-fee tolerance, so the member didn't get a fee. This is because the program that actually writes out those detail records is the same program that posts the fees in the first place. If the f  More...