Answer:
The FDIC has been criticizing Institution’s for not disclosing this possibility. Under Regulation DD, Institutions are required to disclose what can cause overdrafts. The typical language is:
Overdraft fees apply to overdrafts created by check, in-person withdrawal, ATM withdrawal, or other electronic means.
TCA recommends additional changes based on whether or not the Institution offers a Reg E opt-in for ATM and one-time debit card transactions.
- Overdraft fee verbiage for opt-in institutions: Overdraft fees apply to transactions created by check, in-person withdrawal, internal transfer, bank fees, or other electronic means. Overdraft fees will not be imposed on ATM withdrawals or one-time debit card items unless the account has opted in.
- If an Institution does not offer opt-in: Overdraft fees apply to transactions created by check, in-person withdrawal, internal transfer, bank fees, or other electronic means. Overdraft fees will not be imposed on ATM withdrawals or one-time debit card items. The addition of the “bank fee” verbiage covers the service charge angle.
The addition of the “bank fee” verbiage covers the service charge angle.

