New Checking Plans Emerge in Response to Reg E

Already experiencing loss of fee income due to lower transactions and lower OD/NSF fees resulting from higher balances, banks are beginning to develop and introduce new checking products that can supplement these lost revenues.

In place of traditional free checking accounts are value-based accounts that allow customers to customize their account for a fee. Features such as identity theft, rewards and even enhanced OD/NSF protection can be selected from a menu of enhancements that allow a bank to replace some of the fee income that already has been lost or will be lost in response to Reg E.

One of the first to build a new array of checking accounts was BBVA Compass which introduced Build to Order Checking more than two years ago.
With a foundation account that features online banking and bill payment, customers can select from a list of additional features for $2 a month. These range from double reward points or cash back on transactions to a free OD waiver, free foreign ATM transactions or interest on the acccount. Customers can even change the features they prefer as their checking behavior changes. According to representatives from the bank, this account represents approximately 80% of the new accounts opened. A few months ago, BBVA Compass expanded their product line to include a small business version of the Build to Order Checking.

Another interesting alternative offered by some banks is an account with a line of credit attached to cover any overdrafts on the account. Not necessarily new to the banking world, some of these accounts with a line of credit are regulated by Reg Z as a credit product as opposed to Reg E, which covers electronic payments.

Finally, there are some banks that are developing a much stronger online checking product with debit transactions and online bill payment requirements while some banks are linking checking accounts with savings accounts to enhance relationship depth and profitability.

It is clear that we are seeing a new wave of product innovation in response to market conditions and the upcoming new transaction regulations. I will continue to share new ideas as they are introduced.

Consumer Trust in Banks Continues to Challenge Bank Marketers

While not approaching the high levels experienced before the financial crisis, Americans are slowly starting to show trust in their financial institutions and believe they have their best interests in mind, according to Forrester Research, Inc. But the positive sentiment is not evenly distributed.

Perennial customer experience leaders like USAA and American Family Insurance continued to top the list and bounced back higher than banks and investment firms. Customer experience ratings for super-regional banks like PNC Bank, U.S. Bank, and BB&T also improved significantly from last year
while the largest banks in the US, such as Chase and Citibank, fell to the bottom of the rankings. As can be expected, investment firms and wealth management firms as a group got the worst customer advocacy ratings overall.

So what does this mean for bank marketers? Many banks would be well served to set their brand apart from the industry as a whole and to emphasize ways your bank has your customer's best interest in mind. This can be done through customer advocacy programs and integrated into every communication to consumers. This is especially important as we move towards the communication of Reg E to customers and try to position 'opting in' as a beneficial option for some customer segments as opposed to a way to generate revenues for our banks.

New York Times Attacks Chase Bank's First Reg E Communication

Chase Bank has already begun communication around Regulation E, and the New York Times (and more than 50 additional media outlets) are reacting quickly with a review of their direct marketing testing in an article titled, "Banks Apply Pressure to Keep Fees Rolling In". The article made special note of the part of the Chase mailing that stated, “Your debit card may not work the same way anymore, even if you just made a deposit. Unless we hear from you.” According to the NYT, the mailing continues to warn (in big red type), “If you don’t contact us, your everyday debit card transactions that overdraw your account will not be authorized after August 15, 2010 — even in an emergency,” with 'even in an emergency' underlined. Additional toned down versions of communication are also being tested by Chase, including a postcard that simply asks customers to be ready for future ways to say yes to debit card overdraft coverage.


As expected, the article positions the mail in a somewhat biased manner as the first in a series of heavy handed customer communications from banks across the country to maintain the high level of fee income currently generated. While the article references many industry marketing experts, most are quoted around how they are helping banks get customers to opt-in as opposed to referencing the experts who have done research around why consumers do not want OD coverage to cease.

From this initial outcry, it is apparent that banks will need to be careful as to the way they balance the communication of education around Regulation E with the desire for the most impacted households to continue to be covered. The New York Times article also illustrates the pressure our industry will feel in the coming months around the fees we charge for these services.

Segment Your Customer Base For Reg E Communications

The recent changes to Reg. E, impacting how financial institutions can levy fees for overdrafts caused by one time debit card or ATM transaction, have created a period of both challenge and opportunity for financial institutions. Due to the almost certain negative impact on a bank’s fee revenue and potential customer confusion about this new regulation, it is important to be able to effectively and efficiently implement these new requirements, maximizing account holder opt-in responses while providing a positive customer experience.

In this month's ABA Bank Marketing Magazine, Robert Giltner from Velocity Solutions suggests that financial institutions should start their communications process with a mass mail and email campaign to all customers explaining the new regulation. While I agree that all customers should be provided a clear understanding of their options, I don't agree that an all encompassing direct mailing should be done from a cost perspective.

Every customer should not be treated the same. Research shows that while most customers do not like the fees associated with overdrafts, there is a percentage that rely on overdraft coverage to meet current expenses or avoid embarrassment caused by inadequate record-keeping. To achieve the highest possible opt-in response at the lowest possible cost, I believe a segmented and integrated communications process should be used, leveraging multiple communication and response channels and focusing resources where they will have the greatest impact.

Instead of treating all account holders the same, most financial institutions I have talked to will be communicating most aggressively to the 10-15% of the customers who have the highest incidence of overdrafts, connecting with those households that the FDIC found to be the highest users (and fee generators) in their 2008 Study of Bank Overdraft Programs.

Some firms are even trying to determine which owner on an account is responsible for the majority of the overdrafts. By using all available communication channels (direct mail, statement inserts, email, POS, phone, and branch level communication), banks are hoping to communicate the benefits of opting-in to the customer, thereby minimizing the fee income impact of the regulation while improving the customer experience. The majority of the customers who do not overdraft their accounts will be more efficiently reached using a series of statement inserts, statement messages, branch level POS, ATM messaging, email, etc as opposed to postal mail.

I believe the most difficult challenge may be after the regulation takes effect in August, when customers who were not frequent overdrafters experience their first rejected ATM transaction or debit card purchase.

Checking 2.0 Executive Forum to Discuss Reg E Strategies and Economics

On March 23 in Atlanta and April 20 in Chicago, I will be presenting along with leaders from Novantas, the Federal Reserve and others at BAI's Checking 2.0 Executive Forum. This one day session in two cities will allow senior banking executives to receive proprietary research and interact with peers in discussions around the best ways to respond to changing legislation impacting checking accounts. My lunchtime presentation will leverage the findings of research presented by BAI and Novantas, discussing ways banks are approaching the communication of Reg E changes with their customers and how future marketing initiatives will be impacted by this new legislation.

Bank of America's Overdraft Announcement is Great PR

Yesterday, Bank of America announced its intention to end its overdraft fees on debit and ATM transactions beginning this summer. Instead of being assessed a fee, the transaction will be denied unless a customers wants to opt-in to overdraft protection. The advertisement in today's Wall Street Journal positions the decision as a way to help customers from overdrawing their accounts and to provide more control and choice for their customers.

The problem is, Bank of America isn't doing anything that isn't already required by the Federal Reserve. They are just avoiding the cost of communicating with all of its customers to ask them to opt-in (at least for now). Excuse me if I don't believe that they will just walk away from millions of dollars in OD fee income.


In fact, I suspect customers will soon be confronted by messages on ATMs and discussions in branches to encourage them to opt-in much like all other banks are doing. There may even be a program to automatically offer a line of credit 'advance' if a person is about to overdraw their account at an ATM or at a retail POS location. Much like a credit card overdraft, the transaction could be interrupted by the opportunity for a customer service call where a representative offers a small line of credit to allow the purchase to continue as desired.

And there would still be a fee for every transfer made between linked accounts or from the reserve account.

Credit Bank of America for a very well timed public relations announcement, especially in light of the poor communication done by Chase Bank in some of their opt-in mailings. But be careful to give too much credit when the goals of Bank of America at the end of the day appear to be similar to most other banks. And expect most competing institutions (except Citi where there are no overdrafts) to begin to tout 'choice' as their response to Bank of America automatically opting-out all customers.

Reg E Provides Opportunity for Enhanced Relationships

While many banks initially viewed the primary objective of Reg E communication as the recapture of potentially lost fee income, many banks are now positioning their Reg E communication around expanded overdraft options including linked accounts, checking reserve lines of credit and even electronic alerts. While the 12-18% of a bank's accounts that have had overdrafts in the past 12-24 months may still receive messaging primarily focused around opting-in, segmentation strategies will allow banks to reinforce the benefits of alternative overdraft protection to the roughly 80% of the households that do not generate revenues from fees or from higher balance spreads.

The benefit of communicating to a broader audience with alternative options is that the linking of accounts or the opening of a reserve line of credit can extend the life of a checking customer relationship by 2-3 years, thereby eliminating the replacement cost of the customer which can be between $200-$250 based on industry research. The value of this extended relationship far outweighs the potential for fee income for the mass market customer.

In addition, with media attention on Reg E, there is the opportunity to leverage this coverage and enhance the customer experience by educating the mass majority about overdraft coverage options available.

Free Checking Obituary

Seeing that a lot of industry writers seem to be already announcing the death of Free Checking as a likely outcome of Reg E, I thought it would be appropriate to write an obituary for this product that saw such an active and successful life.

While many may claim to be the father of this service, paternity tests will most likely point to Ralph Haberfeld as the individual who most nurtured this service during the formative years and who was the strongest proponent of the benefits of the fee income associated with Free Checking. Ten years ago, when some banks (and consultants) began "pushing" free checking, there was concern about losing the meaningful income of monthly fees associated with traditional checking accounts.


Well, here we are, ten years later, having the same concerns about NSF/OD fees. These fees, that grew faster than the growth of checking accounts, became the prime fee income driver of well over 60% of our industry in this past decade. Ever since the introduction of these fees, banks have found ways to optimize the opportunity with strategies such as 'large to small' check presentment order.

The Fed said it focused on ATM and debit card transactions for Reg E because these have been "a key driver behind the growth in the volume and cost of overdraft fees" (41% of NSF transactions). Finally, consumers and regulators both balked, which is, in part, why we're facing increased scrutiny and regulation.

So, is Free Checking really dead? Free Checking coupled with overdraft protection is a product that is still highly valued by a small but important segment of customers who prefer to use overdrafts as a way to make ends meet at the end of the month. The outgrowth of Reg E will most likely be pseudo Free Checking that includes relationship stipulations (direct deposit), transaction requirements (minimum number of signature debits) and/or channel restrictions (no teller access). There may even be Free Checking as we know it today for those households that decide to opt-in.

In other words, rumors of the death of Free Checking may have been greatly exaggerated.

Chase Card Innovation Gives More Control to Customers

Last September, Chase Bank introduced Chase Blueprint, an innovative set of features that improves the way customers can manage their credit cards with tools to pay down balances, manage spending and pay off major purchases. Available at no charge to more than 20 million consumer and small business Chase credit card customers, Blueprint is fully integrated into the account and consists of four unique features that Chase calls Full Pay, Split, Finish It, and Track It.

The components of Blueprint provide the following benefits:

• Full Pay: The customer can set aside which charges they want to pay off in full on any given month and avoid paying interest on those items (groceries)
• Split: Lets the customer select the number of payments or monthly payment amount for things like large purchases (appliance or home improvement)
• Finish It: Simply select a date that a customer wants to pay off a purchase and Chase does the math to determine the monthly payment and provides charts to show progress
• Track It: Provides the ability to see spending by category online on demand as opposed to annually like most card companies.

According to Caryn Kaiser, Senior Vice President from Chase, the Split feature has the highest levels of customer satisfaction since the introduction of the program. The Track It feature has also resonated with affluent customers who want to know where their dollars are going.

The development of Blueprint arose out of customer research that showed that consumers usually hold multiple credit cards for specific purposes. It is hoped that by offering this capability within one card, consolidation of balances will occur and retention will improve.

While other banks may try to follow Chase's lead, this integrated set of credit card benefits do not seem easy to replicate, giving Chase a 'first mover' advantage. I also expect Chase to follow-up this innovation with similar innovation on the debit card side around rewards, alerts and tracking of purchases. The timing of these changes will most likely coincide with the massive media attention around Regulation E.

Don't Forget Small Businesses With Your Reg E Communication

While small businesses are not impacted directly by Regulation E, many of the banks at the Atlanta BAI Checking 2.0 Executive Forum where I spoke last week indicated that they will be reaching out to their small business customers to explain the law and the potential impact on their retail business.

Not only do many smaller businesses use consumer checking accounts for their small business transactions (with the potential for debit card rejected transactions), but with the potential for so many customers of small businesses having payments for goods and services rejected after the implementation of Reg E, banks are communicating details around this consumer legislation and options as to how to deal with transactions that are rejected.

BAI Checking 2.0 Executive Forum Recap

I just finished presenting at the second BAI Checking 2.0 Executive Forum in Chicago where close to 50 financial institutions learned about legislative changes, customer perceptions, new product development and marketing opportunities around the checking account. While only a month has passed since the first Checking 2.0 Executive Forum held in Atlanta, it is obvious that there are a number of changes occurring in the marketplace.

There was consensus among the participants that while consumer trust and confidence in banks has been negatively impacted by the events of the past two years, there may be some uptick in these measures over the next few months if financial results continue to improve and if banks continue to focus on the customer experience.


A significant change from the March event was that virtually all of the participating banks have developed an alternative version of 'Free Checking'. Checking account product innovation has added stipulations to some accounts, benefits for a fee on others and alternative reward structures on other checking programs. In fact, in a quick survey of the participating banks, it did not appear that any of the 'Free Checking' programs were similar.

When discussions moved to how banks are responding to Reg E, there were some organizations that were well on their way towards communicating with their customer base while other banks had not yet begun their information dissemination. Surprisingly, MB Financial out of Chicago shared that they had already achieved close to 85% opt-in from their customer base (and nearly 100% from new customers) by leveraging a combination of postcards, traditional direct mail, phone call follow-up and branch level involvement.

The success of some of the participating banks illustrated the importance of a multi-channel communication process with strong employee involvement and call center follow-up.

Chase Uses Safety Message to Promote Signature Debit

Chase Bank has recently reached out to their converted WAMU customers who are receiving a newly branded debit card asking them to "always select 'credit'" when paying for their debit card transactions, stating that the transaction is actually safer than entering a PIN.

The slightly confusing message has not gone unnoticed by industry experts who have come out on both sides of the argument around safety. According to an article in the April 21 edition of American Banker, consultants from Gartner and Aite believe that the PIN provides an added level of security, and that the Chase message may be driven more by the opportunity to generate the higher interchange income associated with a signature based transaction as opposed to a PIN transaction.


Alternatively, Marite Ferrero, CTO of France's CardSwitch Technology, stated on April 22 that he believes the pen is mightier (and safer) than the PIN since fraudsters who skim a customer's mag stripe can use the captured PIN to perform non-personal transactions at an ATM and online.

Whether the Chase message resonates with customers as much as the significant incentives and rewards offered by Chase and most other large and small banks for signature based transactions remains to be seen. From what I have heard in my travels over the past couple months, however, the Summer and Fall spending seasons will most likely see a significant uptick in mass media and direct marketing promotions to get customers to change their debit card transaction habits. With Reg E expected to negatively impact fee income, almost all institutions will need to find new ways to cover the cost of checking and related services.

Seven Predictions for the Future of Banking

Today, Susan Wolfe, Vice President of Financial Services from Mintel Comperemedia, presented a webinar entitled, "Seven Predictions for the Future of Banking" where she explored trends in the industry based on the research and direct marketing examples from their custom consumer surveys and mail panel. Each of these trends correlate with what I have seen in the marketplace even though many trends have been impacted by the massive influence Reg E has had on the focus of many bank marketing departments over the past few months.

The predictions presented in the Webinar were:

1. More Aggressive Focus on 'Relationship Banking': Even though trust in banks has waned lately, banks are emphasizing the building of a stronger relationship through integrated accounts like Fifth Third's Relationship Savings Account and with rewards programs like PNC Bank's points.
2. Increased Promotion of Account Builder Programs: Responding to a much higher savings rate, especially by higher income segments, new products are being introduced such as SmartCents by Capital One and U.S, Bank's S.T.A.R.T. program.
3. More Debit Card Marketing: With the loss of overdraft fee income, banks will encourage debit card use for automatic bill payments and will begin to share interchange income with per use rewards programs and sweepstakes.
4. Continued Importance of Incentives: As mentioned my recent Blog, incentives for opening new checking accounts have increased and are becoming more widespread. BBVA Compass also offers incentives through an offline and online refer-a-friend program.
5. Mobile Banking is the 'New' Online Banking: While the adoption of mobile banking currently is inversely correlated to age, this trend could easily reverse as offline sign-up expands and promotion of text messaging and electronic alerts increases. Bank of America has around 3 million subscribers with the majority using an iPhone or iTouch. Online money management tools also continue to become more sophisticated such as those from Mint.
6. Proliferation of Financial Literacy Programs: Banks are focusing efforts on new programs to help customers better understand and manage their finances such as Chase's Blueprint and Bank of America's financial education website.
7. Expanded Testing and Use of Social Media: Financial services firms continue to test ways to leverage social media such as American Express's online booking app on Faceboook, Bank of America's help page on Twitter, Chase's Facebook charitable giving event and Stagecoach Island from Wells Fargo.

Interchange Amendment Could Change Reward Programs

As if we haven't seen enough regulatory changes over the past 12 months with the Card Act and Reg E, now there is the possibility that Washington will limit interchange fees for debit transactions.

As noted in a recent Client Briefing from Celent Research, part of the proposed legislation requires the Fed to determine a “reasonable and proportional” interchange fee, which is no easy task given that interchange fees are there to balance the incentives in the payment system and tend to cover such difficult-to-quantify items as the payment guarantee and convenience.

In other words, the government can't look at just the operational and fraud prevention costs. In addition, current interchange fees differ by sector and are not standardized currently.


As was the case with the other two payments legislations already enacted, the idea behind the interchange amendment is to protect the consumer and lower prices (in this case, the thought that merchants will pass the banking savings on to the consumer). Given the financial times and the narrow margins at many retailers, the passing along of reduced costs is unlikely. In reality, the consumer is likely to lose on many fronts.

If interchange income is legislated at a lower level, banks will most likely raise fees on alternative services to compensate. So instead of the merchant picking up some of the burden, the consumer will be directly impacted. In addition, with more and more banks heavily promoting rewards programs on debit cards, these programs will need to be significantly restructured or eliminated altogether. This may have a bigger impact on smaller banks and credit unions than larger banks where costs can be spread. Some banks may be forced to stop issuing cards which is why community banking associations and CUNA are aggressively fighting this proposed bill.

In the end, banks will most likely be forced to find alternative revenue sources and potentially new ways to structure rewards programs with stronger merchant involvement. New programs such as that offered by Cardlytics (covered on April 29) or fee-supported rewards programs such as the program at KeyBank may be viable alternatives.

Reg E Opt In Results Better Than Expected

As I travel across the country and talk to bankers about their early Reg E opt-in results, many are experiencing significantly higher than expected acceptance rates. In fact, some banks have indicated that they have achieved opt-in rates of as high as 85% or more from the highest impacted segments (those who have the highest use of overdraft coverage) and more than 95% from new customers who are opening a new account.

This level of acceptance should provide some comfort to financial institutions who have been concerned about a massive outflow of fee income as a result of Reg E beginning on August 15. Alternatively, this level of opt in sets the bar rather high for those organizations who have either not begun their Reg E communication or had thrown in the towel expecting customers to opt out on a massive basis.


In talking to those bankers who have achieved best-in-class results, here are the consistent strategies for success:

• Connect with customers using as many channels as possible - While response to statement inserts, direct mail and ATMs has not been as strong as the outbound telephone, 1:1 branch contact and email channel, the most successful banks have used all channels to provide a clear understanding of the regulation and to generate response.
• Use all outbound phone capabilities available - When a direct connection is made with a customer discussing the option of 'keeping their coverage the same' and 'having the assurance of no surprises', success rates have approached 90+%. Banks are using all of the resources possible to make these calls, including branch call nights, outsourced providers and leveraging inbound call resources.
• Expand communication beyond high opportunity segments - Instead of only connecting with high OD households, the most successful organizations are reaching out to all of their customers regarding opting in. While not having the same immediate financial impact, this communication emphasis will avoid potential negative customer experiences in the future.

As a result of the strong results achieved to date by those banks who started early, most of the financial institutions I have talked to have communication strategies that extend well beyond August 15. While the regulation takes effect on that date, most banks are going to continue mailing and call efforts until they have reached as many households as possible. Obviously, knowing that an 80+% acceptance rate is possible provides the financial incentive to not approach this effort casually.

Chase Introduces Instant Action Text Alerts to Allow Customers to Avoid OD's Immediately

In the February 2010 Javelin Strategy and Research report on financial alerts, some of the major flaws of current alerts included difficulty of setting alerts up, lack of timeliness, not actionable enough and poorly marketed. In addition, the research found that one of the highest utility features from both a customer and bank perspective is the ability to alert and respond to potentially insufficient funds.

Expanding on their very popular low balance alert mobile banking feature, Chase Bank just introduced a new feature that addresses many of these flaws by allowing customers to easily respond to a low balance alert from the bank by immediately transferring funds through text messaging.


The new feature will allow customers to transfer funds from any eligible checking, savings or money market account simply by typing the letter "T" followed by the dollar amount of transfer desired (for instance, to transfer $100, the customer simply types "T 100"). If the customer has more than one eligible account with adequate funds, both accounts with the balance available to transfer will be shown, along with the option to use either account to fund the low balance account.

To be eligible for this service, a customer simply needs to be a Chase Mobile customer, have the ability to send and receive SMS texts, and sign up for the Instant Action Alerts. As an added benefit, the customer can even set the time they want to receive notification during the day.

While not promoted on the Chase homepage as of this writing, an animated landing page (shown above) is being used in conjunction with Google AdWords using search terms like "overdraft alerts" and "mobile banking alerts".

Payments innovation is becoming more and more commonplace with Chase Bank as indicated in several of my Blogs this year, including the introduction of Chase Blueprint. These innovations in most cases enhance the customer experience while also reducing operating costs. It will be interesting to see what other innovations are on the way from Jamie Dimon's team.

Alternatives to Online Bill Payment May Drive Stronger Engagement

Research has shown that one of the strongest engagement tools for new and existing checking customers is to have the customer set up online bill payment. Unfortunately, even with aggressive 'switch' programs, the success banks have had trying to get customers to sign up for online bill payment has been less than overwhelming.

To try to simplify the signing up for online bill pay (and reduce first year attrition), some banks have moved to promoting the payment of bills using debit and credit cards. In the case of using a debit card, the payment still is taken from a customer's checking account and the process for signing up can actually be easier than with a traditional biller. In addition, using a debit card for bill payment can generate interchange income for the bank, rewards for the customer, and if the payment is recurring, it will not be subject to the new Reg E stipulations.


Chase Bank has done an excellent job of promoting bill payment using debit and credit cards through an online tool called Chase Payee Directory. With this tool, a customer can select the company they want to pay with an interactive directory.

With the goal of getting new and existing checking customers to use their checking account becoming as important as retaining the customer, these forms of moderate innovation will certainly become more commonplace.

The Mobile Banking Response to Reg E

In a June 9 webinar entitled, Mobile Alerts and Reg E presented by Javelin Strategy & Research in conjunction with ClairMail, there was a great discussion of how mobile banking and financial alerts can play an integral role in both the opting-in process and the enhancement of the customer experience after August 15.

By providing enhanced information about the customers accounts and allowing the customer to be 'in control,' the perceived value of mobile banking can be enhanced. In addition, the ability to use mobile banking alerts to help avoid OD and NSF fees enhances the value of the device even more. It was mentioned that as many as 90% of customers who receive alerts will actually take action based on the alert (through signing on to their online banking account (33%), calling (33%) or visiting the branch (14%)).


The ways mobile banking can assist a customer would be real time alerts, real time account balances, two-way interactive alerts and transfers (like the Chase Bank introduction recently), and mobile PFM tools. In other words, mobile enables a highly personalized, proactive interaction with the bank when an overdraft occurs.

From the bank's perspective, Clairmail emphasized that the mobile channel enables banks to generate new revenue, increase satisfaction, drive adoption and retention and help to eliminate customer distrust of the bank thanks to enhanced transparency. In addition, the mobile channel can allow the bank to cross-sell overdraft solutions at the time the customer can relate the most . . . when they about to have a transaction rejected or a fee imposed.

PNC Uses Social Media to Support Reg E Efforts

It appears PNC Bank is leveraging all available channels in their effort to capture as many opt-ins as possible. Today, I received a Tweet from PNC Virtual Wallet offering a description of the difference between overdraft protection and overdraft coverage. The message directed me to my Inside the Wallet Blog within the Virtual Wallet online banking site.

On the Blog, PNC innovation and Virtual Wallet leader Michael Ley, describes the options a customer has as to whether to opt-in or not with his post, "To “Opt In” or not “Opt In”… What is the Question?". Illustrations are used to help describe the options a customer has.

If after I read the Blog posting from Mike Ley, I still want more information, I am directed to the PNC overdraft solutions landing page for all the answers to Reg E questions as presented using a video presentation from the head of deposit products at PNC, Todd Barnhart. In addition to the very clear video, further descriptions are provided around overdraft solutions, including several overdraft protection options (with direct links) as well as the pricing schedule for overdraft protection. The site also has an extensive FAQ section and more ideas around managing money.

Overall, the integration of online and social media communication in addition to traditional direct channels used by PNC will most definitely improve the bank's Reg E opt-in rate. It will be interesting to see the ways in which other banks get their regulatory message out and the success rates experienced.