We're On It!
As always, IMPACT Financial Services takes a proactive approach to regulatory compliance issues. Over the course of the next weeks and months, we will be communicating our plan of action to address all compliance, design, and technology changes mandated by the new regulations.
We will be communicating this information via multiple media sources such as this website, our client services portal, informational webinars, blast emails, and regular mail.
All our clients should have already received some preliminary email communications. If you have not received such communications, please call our Support Services Department for assistance at (877) 280-9120.
All information that is sent out will also be availalble on our secure client services portal, so be sure to check back regularly for updates.
Portal Login
Click HERE to access our secure client services portal.
If you do not know your user name and password, please contact IFS Support Services at (877) 280-9120.
IFS Update On Regulation E
In November 2009, the Federal Reserve released a Final Rule and official staff commentary (the “Final Rule”) under Regulation E. IMPACT Financial Services has the solutions you will need to meet the new requirements. Please be advised that the changes required for Reg E are not effective until July 1, 2010. We strongly advise our clients to NOT make any changes to their programs at this time. We will provide our clients with a detailed description of IMPACT’s strategy to minimize loss of revenue, and provide ease of compliance with the new requirements by the end of January.
The Final Rule requires financial institutions to provide consumers with the right to Opt-In, or affirmatively consent, to the financial institution’s overdraft services for ATM and one-time, non-recurring debit card transactions. No fee for these overdraft services may be assessed without the consumer’s affirmative consent. (Login to our Client Services Portal to view the IFS Analysis of Regulation E (EFT) ATM and Everyday Debit Card Opt-in Mandate)
Industry experts have estimated that this change may result in a loss of fee revenue of more than $15 billion annually to the financial services industry. The Final Rule applies to all consumers, including existing accountholders, but excludes business or commercial accounts.
Opt-In consent requirement: After July 1, 2010, financial institutions will be required to conform to the following before assessing fees for ATM and debit card services:
1. Provide written notice describing the financial institution’s overdraft service, fees and charges in detail (this notice must be segregated and separate from all other account disclosures).
2. Provide a reasonable opportunity for the consumer to Opt-In to the service.
3. Obtain the consumer’s affirmative consent.
4. Provide the consumer with written confirmation of the consumer’s consent including a statement informing the consumer of the right to revoke such consent at any time.
Because of IMPACT’s approach to overdraft protection services and compliance, our clients are well positioned to implement the above changes and fully comply with all aspects of Regulation E. IMPACT will provide our clients with materials updated to meet these requirements including: a plan design, documentation, disclosures, Reg E specific accountholder communications and forms, employee training materials and updates to your overdraft management software to ensure ongoing compliance.
In addition, IMPACT will offer an optional service, The IMPACT Optimizer, to help maximize opt-ins and sustain our clients’ overdraft fee income. The service will include the following:
- Web hosted solution—no hardware or software license purchase required
- Consumer notification and confirmation via direct mail and/or e-mail.
- Comprehensive marketing plan to optimize accountholder opt-in to ATM and Debit Card Services
- Tracking of Opt-Ins, Opt-Outs, Confirmations and Revocations
We will release more information in the coming weeks concerning this valuable new service.