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.