Opt In/Opt Out Reg E Settings
For an overview of the Reg E Opt In/Opt Out features in CU*BASE, refer to the bookletManaging Your Opt In/Opt Out Reg E Offering.
CU*BASE can assist you with the task of complying with regulations. “Opt In/Opt Out” check appear on several screens in CU*BASE to assist you in recording members’ selections, including during membership opening, membership updating, account opening, and via an Opt In/Opt Out Maintenance screen accessed via Member Personal Banker, Phone Operator, and Inquiry. Each time a credit union employee records a selection, the date and Employee ID is recorded.
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NOTE: You cannot change the membership designation of an account if the member has elected to "opt out" (of a single account or all accounts.)
Recording “Opt In/Opt Out” Preference When Opening a Membership
While opening a membership, your employees can use new check boxes, very prominently displayed at the bottom of the screen, to indicate the member’s preference to either “Opt In” or “Opt Out.” A selection is required to advance to the next screen.
Something to Think About: Reg E functionality in your credit union’s member Workflow Controls determines whether one of these “Opt In/Opt Out” boxes (shown above) is pre-checked on membership open. This Workflow Control setting is defaulted to “Required,” (neither check box is selected automatically, but a selection is required), but you can change this setting to always check the “In” box or the “Out” box when a new membership is created, depending on your credit union procedures. (Your employee can always change the selection if your member’s preference is the other option.) If you want to control the default setting for new memberships, useMember Service Workflow Controls (Tool #1004: Workflow Controls: Open Mbrships/Accts).
Recording “Opt In/Opt Out” Preference for Existing Members
You can also record preferences using the Opt In/Opt Out Maintenance Screen..
For members that Opt In, there is an additional feature that lets you specify an exception to the member’s preference at the sub- account level. This is intended to be used in rare cases where a member specifically asks to Opt In to your overdraft services, but wants to exclude a certain individual account, such as a member who has an account that she uses for a small home business flower shop, and doesn’t want that account to be handled the same way as her personal accounts. (NOTE: The member must first “Opt In” at the membership level in order to set this exception.)
Remember that from a sales and member service standpoint, you want to make this as simple for your members as you can. So it’s important to sell the idea of “opting in to your credit union’s overdraft services” program (whatever that may be), and flagging the member accordingly. Only in rare cases where a member specifically asks for an exception would you ever need to deal with the sub-account flags. This should make the workflow much more streamlined, and avoid your having to ask the member over and over again what their preference is on each individual account. If they are IN, they are IN for all accounts (current and future) unless they specifically request an exception.
Access the Opt In/Opt Out Maintenance Screen through a new Reg E Opt In/Out Preference selection in Member Personal Banker or through Inquiry and Phone Operator. For Inquiry and Phone Operator first select OTB Cards (F17) (which takes you to the screen where you can record the setting.
Membership Update is another route for “Opt In/Opt Out” selection. This screen contains the same prominent “Opt In/Opt Out” checkboxes you see when you open a membership; however, when you access the membership screen through update a selection is not required. (You might just be changing a member’s email address and not have the member right in front of you to ask for his or her preference.) Employees can also note exceptions at the sub-account level by using Reg E Exceptions (F13) from this screen.
NOTE: You cannot change the membership designation of the membership if the member has elected to "opt out" (of a single account or all accounts.)
Recording “Opt In/Opt Out” Preference When Opening a Sub Account
Members opt/in opt out status can be collected when they open a sub account as well. Prominent checkboxes assist in the collection of this selection during this process. If the member has already made a selection, the appropriate box will already be checked. The employee can then make or change the selection at this time. (If the member selects to “Opt In," they can use the Opt In/Opt Out Maintenance screen to Opt Out for certain sub-accounts.