FIND THE EXPLANATION
Separate an installment loan, credit line, and negative deposit account before treating them as the same bank debt.
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Actual research-check date: October 27, 2026, America/Los_Angeles. The clock check at 22:02:18 UTC corresponds to 15:02:18 PDT on that date. Dates below distinguish publication, enactment, regulatory effectiveness, compliance triggers, and the date a source was accessed.
Research scope: Generic published federal law, official interpretations, final-rule materials, and a generic model form. No consumer, institution, account, transaction, provider, license, case record, docket, or identifier search was conducted. No form was completed or submitted. No prior report or Library material supplied a foundation. No subagents, browser control, separate research session, or local coordinator files were used.
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Two material source qualifications remain:
For an otherwise covered consumer account and overdraft service, the account-holding financial institution may not assess a fee or charge for paying an ATM or one-time debit-card transaction unless it satisfies all four requirements:
Affirmative consent is one requirement within that sequence. A signed general account agreement, a preselected box, continued account use, or the fact that a transaction was paid does not establish the required separate affirmative consent. Claims C029–C039 below separate these requirements and their timing. ecfr.gov+2
The institution may pay a covered overdraft without consent without charging for doing so. The commentary preserves its ability to debit the amount overdrawn only if otherwise permitted by applicable law. Conversely, an opt-in does not require the institution to authorize or pay an overdraft. This pass therefore determines neither an actual principal debt nor a right to collect it. C057–C058. Consumer Financial Protection Bureau
The relevant account ordinarily must be a consumer asset account established primarily for personal, family, or household purposes, and the consumer must be a natural person. A natural person’s business-purpose account is not converted into a covered consumer account merely because it has a debit card. Banks and credit unions fall within the relevant financial-institution definitions; the regulation also reaches certain other account holders and access-device issuers. The specific § 1005.17 duty is directed to the account-holding institution, and its debit-card scope depends on issuance by or on behalf of that institution. C002–C006, C018, C059. COMMERCE AND TRADE+4
The definition of overdraft service excludes specified arrangements: Regulation Z credit lines, transfers from another account held individually or jointly by the consumer, specified securities or commodities credit, and the particular prepaid-credit arrangements described in § 1005.17(a)(4). A negative balance alone does not identify which arrangement exists. C019–C025. Consumer Financial Protection Bureau+3
The opt-in fee prohibition targets ATM and one-time debit-card transactions. It does not impose the same opt-in prerequisite on paid check, ACH, or recurring debit-card overdrafts. An ACH transfer may be an electronic fund transfer under Regulation E without becoming a one-time debit-card transaction under § 1005.17.
The commentary permits reliance on third-party transaction coding if the institution has adapted its systems to distinguish one-time from recurring transactions. Actual coding, the system condition, the payment arrangement, and the underlying channel remain unknown here. Repeated payments to the same payee do not, by themselves, establish the applicable classification. C007–C016, C059–C061. Consumer Financial Protection Bureau+3
For a consumer who has not opted in:
These are conclusions about this section’s prohibition. They do not establish that a fee is valid under every other law or the contract. Deposit allocation, posting order, associated fees, intervening credits, and the contractual fee trigger remain necessary factual holds. C064–C070. Consumer Financial Protection Bureau
Section 1005.4 supplies the general clear, understandable, retainable-disclosure framework. Section 1005.17 specifically permits electronic notice and confirmation if the consumer agrees.
The original adopting final rule expressly explains in footnote 32 that electronic disclosures under this section are not subject to E-Sign’s consumer-consent and other applicable provisions because the disclosures are not required solely in written form. The same footnote preserves the clear, understandable, retainable requirement. The 2010 clarification separately explains that an oral notice or oral confirmation does not satisfy the rule.
Accordingly, the audit must distinguish agreement to electronic delivery, separate affirmative overdraft consent, and delivery of the required confirmation. I have not added E-Sign’s demonstrated-access procedure as a separate § 1005.17 prerequisite. Other disclosures furnished in the same relationship can present independent E-Sign questions. C030–C034, C037–C038. Consumer Financial Protection Bureau+4
The current official commentary expressly addresses an institution that does not provide an opt-in notice, authorizes an ATM or one-time debit-card transaction believing funds are sufficient, and later pays it when funds are insufficient at settlement. It says the institution may not assess an overdraft fee for paying that transaction. A general practice of declining insufficient-funds authorizations does not create an exception. C062–C063. Consumer Financial Protection Bureau
Where a compliant opt-in is stipulated, § 1005.17 and the passages read do not resolve every authorization/settlement, available-balance, disclosure, unfairness, contract, or other legal issue. The broader legal basis is held. No court holding or later litigation status is asserted. C088–C090.
The December 30, 2024 final rule, Overdraft Lending: Very Large Financial Institutions, stated an October 1, 2025 effective date. Public Law 119-10, approved May 9, 2025, disapproved that named rule and provided that it has no force or effect. Its added “covered overdraft credit” interpretation and related new framework are not used as current authority here. The preexisting § 1005.17 rule remains the relevant published opt-in framework. C082–C085. govinfo.gov+4
CFPB Circular 2022-06 on unanticipated overdraft fees and Circular 2024-05 on improper overdraft opt-in practices are listed in the official Withdrawn Guidance register as withdrawn May 12, 2025. Their publisher pages were checked, but their historical analyses are not used as substitutes for operative law. Withdrawal does not itself repeal EFTA or Regulation E, and does not establish that every affected fee is lawful. C086–C088. Consumer Financial Protection Bureau+4
Reading conventions: “Fresh” means accessed in this assignment. Repeated opens were rereads within this assignment, not reuse of a prior report. HTML has no printed-page or PDF-index pinpoint unless stated. PDF indices are zero-based. Sections and reproductions of the same regulation are grouped or expressly identified as related; they are not independent corroboration.
All entries below concern U.S. federal authority and were checked on 2026-10-27 PDT.
| Source ID | Issuer/title and complete literal HTTPS URLs | Exact provisions; printed page / PDF index | Version, effective predicate, status | Fresh-read extent and currentness limits |
|---|---|---|---|---|
| R010-P1-S001 | Congress; GPO, EFTA definitions and rulemaking authority. https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapVI-sec1693a.htm ; https://www.govinfo.gov/content/pkg/USCODE-2024-title15/pdf/USCODE-2024-title15-chap41-subchapVI-sec1693b.pdf | § 1693a operative definitions, especially (2), (6)–(11); § 1693b(a)–(e), particularly (a)–(d). PDF pp. 1645–1648, indices 0–3; its first page also contains the end of § 1693a. | Official 2024 Edition bodies. Statutory authority and definitions; not a representation of a fully audited October 2026 statutory edition. | Fresh, body read. Current OLRC versions of §§ 1693a–b failed; recovery was the official 2024 edition. 2025–2026 statutory lag remains open. COMMERCE AND TRADE+2 |
| R010-P1-S002 | Congress; OLRC, 15 USC 1693l—Waiver of rights. https://uscode.house.gov/us/usc/119-134/t15/s1693l/ | Entire operative paragraph and source credit; HTML, page/index N/A. | Header states laws in effect through PL 119-134, October 20, 2026. Applies to agreements waiving EFTA rights, with express exceptions. | Fresh, complete operative paragraph read. A direct repeat retrieval failed; reopening the previously retrieved reference recovered the body. Compilation label is not a session-law lag audit. uscode.house.gov |
| R010-P1-S003 | CFPB, Regulation E gateway, general disclosures, and ATM-operator distinction. https://www.consumerfinance.gov/rules-policy/regulations/1005/1/ ; https://www.consumerfinance.gov/rules-policy/regulations/1005/2/ ; https://www.consumerfinance.gov/rules-policy/regulations/1005/3/ ; https://www.consumerfinance.gov/rules-policy/regulations/1005/4/ ; https://www.consumerfinance.gov/rules-policy/regulations/1005/16/ | § 1(a)–(b); necessary § 2 definitions, including (a), (b), (e), (f), (h), (i), (k), (l), with relevant comments; § 3(a)–(c) and embedded interpretations; § 4(a)–(d) and comments; § 16(a)–(d). HTML, page/index N/A. | Agency pages labeled current regulation. Scope and exceptions depend on the account, actor, agreement, transfer, and product. | Fresh bodies read. Full § 2(b)(3) text was read, but its remote tax, benefits, and gift-card cross-references were not comprehensively followed. Full error-resolution, unauthorized-transfer, remittance, and broader disclosure regimes were not examined. Same Part 1005 as S004–S005, not independent corroboration. Consumer Financial Protection Bureau+6 |
| R010-P1-S004 | CFPB/OFR/GPO, 12 CFR 1005.17—Requirements for overdraft services, and official interpretations. https://www.consumerfinance.gov/rules-policy/regulations/1005/17/ ; https://www.ecfr.gov/current/title-12/chapter-X/part-1005/subpart-A/section-1005.17 ; https://www.govinfo.gov/link/cfr/12/1005?link-type=pdf§ionnum=17&year=mostrecent | Entire § 17(a)–(g) and all embedded § 17 official comments, including 17(b)-9.ii.A–C and -9.iii. Annual PDF pp. 204–206, indices 0–2, § 17 only. | CFPB current label; latest eCFR read displayed Title 12 through 2026-10-23 and described eCFR as authoritative but unofficial. PDF resolves to 1-1-26 Edition, source note 76 FR 81023, amended 81 FR 84328. Historical § 17(c) triggers remain printed in current text. | Fresh, complete necessary operative section and interpretations read. Annual PDF parsed text read; screenshots did not yield inspectable pixels. No full post-October-23 publication-lag audit. These are reproductions of one regulatory instrument. ecfr.gov+5 |
| R010-P1-S005 | CFPB/OFR, Current Appendix A, Model A-9, and Appendix A interpretations. https://www.consumerfinance.gov/rules-policy/regulations/1005/a/ ; https://www.consumerfinance.gov/rules-policy/regulations/1005/interp-a/ ; https://files.consumerfinance.gov/f/ER27DE11.000.png ; https://www.ecfr.gov/current/title-12/chapter-X/part-1005/appendix-Appendix%20A%20to%20Part%201005 | A-9 heading and linked graphic; Appendix A comments 1–3; complete A-9-specific instructions in § 17(d) and comments 17(d)-1–5, S004. HTML/PNG; printed page/index N/A. | Current agency appendix presentation; eCFR appendix currency label through 2026-10-23. | Fresh, partial form read. Current instructions and appendix comments read. Current graphic returned an image placeholder, not visible pixels or complete extracted form text. Current visual form comparison remains unresolved. Consumer Financial Protection Bureau+3 |
| R010-P1-S006 | Federal Reserve, generic Model A-9 distributed with the 2009 final rule. https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20091112a3.pdf ; discovery page: https://www.federalreserve.gov/newsevents/pressreleases/bcreg20091112a.htm | Complete one-page form body, parsed lines 0–35; unpaginated, PDF index 0. | Historical November 12, 2009 distribution. S011 expressly describes the 2011 A-9 as substantively identical except “website” spelling. | Fresh, complete parsed historical form text read; pixels not read. PDF metadata labels it an opt-out form, but the actual body and publisher link identify the relevant A-9 consent form; metadata was not substituted for the body. Illustrative fees and periods are not legal limits. Press release used for discovery, not operative dates. federalreserve.gov+2 |
| R010-P1-S007 | CFPB, Regulation Z cross-references necessary to § 17(a). https://www.consumerfinance.gov/rules-policy/regulations/1026/3/ ; https://www.consumerfinance.gov/rules-policy/regulations/1026/61/ | § 1026.3(d), comment 3(d)-1; § 1026.61(a)(1)–(5), especially (a)(2), (a)(4), (a)(5)(iii)(D), and necessary embedded comments. HTML, page/index N/A. | Agency current-regulation presentation. Applied only to the exclusions expressly incorporated by § 17(a). | Fresh, necessary definition/exception bodies read. Full Reg Z lending, APR, origination, repayment, security, and remedy regimes remain held. Historical prepaid-effective-date chain was not comprehensively audited; no historical product application is made. Consumer Financial Protection Bureau+7 |
| R010-P1-S008 | Congress; OLRC, 15 USC 7001—E-Sign general rule. https://uscode.house.gov/us/usc/119-134/t15/s7001/ | § 7001(a), (b), (c)(1)–(6); additional text and effective-date notes also returned. HTML, page/index N/A. | Header through PL 119-134, October 20, 2026. § 7001(c) concerns information legally required in writing; see S009 for the § 17-specific adopting explanation. | Fresh, complete relevant subsections read. Used to distinguish the general statute from the special overdraft disclosure treatment, not to create an extra § 17 consent condition. Compilation-lag qualification retained. uscode.house.gov |
| Source ID | Issuer/title and complete literal HTTPS URLs | Exact provisions; printed page / PDF index | Version, effective predicate, status | Fresh-read extent and currentness limits |
|---|---|---|---|---|
| R010-P1-S009 | Federal Reserve, Electronic Fund Transfers—2009 final rule and official staff commentary. https://www.federalregister.gov/documents/2009/11/17/E9-27474/electronic-fund-transfers ; https://www.govinfo.gov/content/pkg/FR-2009-11-17/pdf/E9-27474.pdf | 74 FR 59033–59056, 24-page PDF, indices 0–23. Relevant read: dates at 59033 / 0; notice discussion and complete footnote 32 at 59041–59042 / 8–9; confirmation discussion 59043 / 10. | Published 2009-11-17; effective 2010-01-19; mandatory compliance 2010-07-01, with existing-account treatment in § 17(c). Historical adopting rule; subsequently clarified and recodified. | Fresh, selected necessary body passages read, not a claimed full 24-page read. Official PDF verified the electronic-delivery explanation. Original former § 205.17(b)(4) is not used as current text. govinfo.gov+3 |
| R010-P1-S010 | Federal Reserve, 2010 clarification and correction. https://www.federalregister.gov/documents/2010/06/04/2010-13280/electronic-fund-transfers ; https://www.govinfo.gov/content/pkg/FR-2010-06-04/pdf/2010-13280.pdf ; https://www.federalregister.gov/documents/2010/06/15/2010-14353/electronic-fund-transfers ; https://www.govinfo.gov/content/pkg/FR-2010-06-15/pdf/2010-14353.pdf | 75 FR 31665–31673, indices 0–8: scope/confirmation discussion, balance-fee discussion, content instructions, and amendatory text. Correction at 33681 / index 0, operative correction fully read. | Both effective 2010-07-06. Clarification removes former (b)(4); correction specifies revision of the (b)(1) introductory text, preserving the subparagraph requirements. | Fresh, selected relevant clarification passages and complete correction read. Current complete comments are independently read as the same regulation in S004. Historical PDF’s final page also contains another rule, which is not adopted as a foundation. federalregister.gov+4 |
| R010-P1-S011 | CFPB, Electronic Fund Transfers—2011 recodification. https://www.govinfo.gov/content/pkg/FR-2011-12-27/pdf/2011-31725.pdf | 76 FR 81020–81058, 39 pages. Necessary read at 81020–81021 / indices 0–1: transfer, recodification, effective date, A-9 change. | Interim final rule; effective 2011-12-30. Rulemaking transfer described as effective 2011-07-21. No new substantive obligations asserted by this recodification. | Fresh, selected body read. A-9 continuity passage fully read. The embedded A-9 graphic was not visually inspected; its exact graphic-page location is not asserted. Not merely a proposal. govinfo.gov |
| R010-P1-S012 | CFPB, Overdraft Lending: Very Large Financial Institutions. https://www.federalregister.gov/documents/2024/12/30/2024-29699/overdraft-lending-very-large-financial-institutions ; https://www.govinfo.gov/content/pkg/FR-2024-12-30/pdf/2024-29699.pdf | 89 FR 106768–106845, 78 pages. Dates 106768 / 0; § IV discussion and § V timing 106816 / 48; complete added comment 17(a)-2 at 106837 / 69. | Published 2024-12-30, stated effective 2025-10-01; disapproved before that date by S013. | Fresh, selected provisions read, not all 78 pages. Used only to identify the exact disapproved change and original trigger. No proposed or disapproved framework is used as current authority. govinfo.gov+2 |
| R010-P1-S013 | Congress, Public Law 119-10, S.J. Res. 18. https://www.govinfo.gov/content/pkg/PLAW-119publ10/pdf/PLAW-119publ10.pdf | 139 Stat. 53 / PDF index 0, entire one-page law. | Approved 2025-05-09. Disapproves the specifically named 89 FR 106768 final rule and gives it no force or effect. | Fresh, complete parsed law read. Screenshot yielded no inspectable pixels; the text body was fully available. No docket or litigation-status inference. govinfo.gov |
| R010-P1-S014 | CFPB, Overdraft Lending compliance resource/status page. https://www.consumerfinance.gov/compliance/compliance-resources/deposit-accounts-resources/overdraft-lending-very-large-financial-institutions/ | “Featured topic” paragraph; HTML, page/index N/A. | Page modified 2025-07-01. Says the final rule has no force/effect and remaining Reg E/Z remain unchanged. | Fresh status paragraph read. Its statement that signing occurred May 12 conflicts with S013’s May 9 approval date. Public-law date controls this report. Resource label does not replace operative text. Consumer Financial Protection Bureau |
| R010-P1-S015 | CFPB, Withdrawn Guidance register and withdrawal notice. https://www.consumerfinance.gov/compliance/guidance/withdrawn-guidance/ ; https://www.federalregister.gov/documents/2025/05/12/2025-08286/interpretive-rules-policy-statements-and-advisory-opinions-withdrawal ; https://www.govinfo.gov/content/pkg/FR-2025-05-12/pdf/2025-08286.pdf | Register’s Circulars & Supervisory Guidance entries for 2024-05 and 2022-06; notice parts I–III and relevant entries. 90 FR 20084–20087, indices 0–3; applicability at 20084 / 0, operative withdrawal discussion 20085 / 1, relevant list 20086 / 2. | Withdrawals applicable 2025-05-12. Register last-modified label 2026-07-22. | Fresh register and necessary notice bodies read. Register and notice are one publisher’s status chain, not independent corroboration. Withdrawal is not treated as statutory repeal or a universal fee validation. Consumer Financial Protection Bureau+3 |
| R010-P1-S016 | CFPB, historical circular publisher pages. https://www.consumerfinance.gov/compliance/circulars/consumer-financial-protection-circular-2022-06-unanticipated-overdraft-fee-assessment-practices/ ; https://www.consumerfinance.gov/compliance/circulars/consumer-financial-protection-circular-2024-05/ | Titles, questions/answers and relevant scope passages; HTML, page/index N/A. Register cites 87 FR 66935, Nov. 7, 2022, and 89 FR 80075, Oct. 2, 2024. | Withdrawn, as verified against S015. | Fresh, limited publisher-page read and status check. Not a full read of every cited authority. No historical enforcement/evidence theory is adopted as current operative law. Continued page availability is not currentness. Consumer Financial Protection Bureau+4 |
| R010-P1-S017 | Congress; GPO, 12 USC 5519—Exclusion for auto dealers. https://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap53-subchapV-partB-sec5519.htm | Entire operative (a)–(f), particularly jurisdictional exclusion, exceptions, preserved authorities, and definitions. HTML, page/index N/A. | Official 2024 Edition recovery. Cross-reference in §§ 1005.2(i), 1005.3(a), and 1693b(a)(2). | Fresh body read. Current OLRC retrieval failed. No dealer, license, entity, or business-line classification was attempted. Statutory lag remains held. BANKS AND BANKING |
| R010-P1-S018 | GPO, full Part 1005 recovery attempts. https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1005.pdf ; https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-part1005.pdf ; https://www.govinfo.gov/link/cfr/12/1005?link-type=pdf&year=mostrecent | 2025 A-9 location: printed 245 / index 60, heading but missing form-body extraction. 2026 full-part header/initial text retrieved; subsequent targeted retrievals timed out. | Annual editions, not October 2026 complete currency guarantees. | Fresh, partial/discovery/failure. No whole-part read claimed. Used to attempt form/text recovery, not independent authority beyond S003–S005. |
Status key: R = operative regulation as currently published in the inspected sources; O = official interpretation; S = statutory text, subject to the stated edition limit; H = historical final-rule explanation or event; D = disapproved rule; W = withdrawn guidance; I = expressly identified inference; U = unresolved.
“Current” below inherits the source-currency limits in S001–S018. It does not represent a completed session-law, litigation, or publication-lag audit.
| Claim ID | Precise claim / area | Source and pinpoint | Trigger, conditions, exceptions | Status / limits |
|---|---|---|---|---|
| R010-P1-C001 | EFTA supplies rulemaking authority for Regulation E; the specific overdraft opt-in conditions are in § 1005.17. | S001, § 1693b(a)–(c); S003, § 1005.1(a); S011, 81021. govinfo.gov+2 | Bureau authority has statutory reservations, including Board authority described in § 1693b(a)(2). | S/R; current statutory-body gap disclosed. |
| R010-P1-C002 | The relevant consumer/account gateway requires a natural person and an asset account established primarily for personal, family, or household purposes. | S001, § 1693a(2), (6); S003, §§ 1005.2(b)(1), (e). COMMERCE AND TRADE+2 | Business-purpose accounts do not qualify merely because a natural person owns or uses them. | S/R; actual purpose unknown. |
| R010-P1-C003 | The account definition excludes incidental credit balances in open-end credit plans and accounts held under bona fide trust agreements. | S001, § 1693a(2); S003, § 1005.2(b)(1)–(2), comments 2(b)(2). COMMERCE AND TRADE+1 | Trust status depends on the actual arrangement and governing law; the comment supplies additional excluded-account examples. | S/R/O; no actual account classification. |
| R010-P1-C004 | Banks, savings associations, and credit unions are included financial-institution classes; the regulation also includes specified other account holders and access-device issuers. | S001, § 1693a(9); S003, § 1005.2(i). COMMERCE AND TRADE+1 | Direct/indirect holding, or access-device issuance plus agreement to provide EFT services, must fit the definition; statutory excluded-person clause remains. | S/R; no named institution or charter inquiry. |
| R010-P1-C005 | The CFPA § 1029 cross-reference is a conditional jurisdictional exclusion, not a blanket statement that all auto-related activity is outside federal EFT law. | S017, § 5519(a)–(c), (f); S001, § 1693b(a)(2). BANKS AND BANKING+1 | Predominant vehicle-dealer activity; exceptions for specified real-property services, retained direct retail credit/leases, and unrelated consumer financial services; other agency authorities preserved. | S; 2024 body, later statutory lag and all entity facts held. |
| R010-P1-C006 | Regulation E account coverage requires an EFT-service agreement of the kind described in comment 3(a)-1. | S003, § 1005.3(a), comments 3(a)-1–2. Consumer Financial Protection Bureau | Consumer–FI agreement, or consumer–third-party agreement with FI notice and transfers begun. ACH membership alone is insufficient. | R/O; actual agreement unknown. |
| R010-P1-C007 | EFT coverage includes qualifying ATM, POS, debit-card, ACH, direct-deposit/withdrawal, telephone, and computer-initiated transfers. | S003, § 1005.3(b)(1), comment 3(b)(1)-1. Consumer Financial Protection Bureau | Must instruct debit/credit of a covered consumer account and survive applicable exclusions. | R/O; channel labels require facts. |
| R010-P1-C008 | A check converted into an ACH EFT differs from a check collected or re-presented electronically as a check. | S003, § 1005.3(b)(2), comments 3(b)(1)-1.v and 3(c)(1)-1–2. Consumer Financial Protection Bureau+1 | Using check information to initiate ACH can be EFT; electronic re-presentment of the original check remains within the check exclusion. | R/O; no transaction coding assumed. |
| R010-P1-C009 | Being an EFT does not by itself bring a transfer within the ATM/one-time debit-card fee prohibition. | S003, § 1005.3(b); S004, § 1005.17(b)(1). Consumer Financial Protection Bureau+1 | The specific transaction must fit § 17’s channel and service conditions. | I from R; one-time ACH is not automatically one-time debit card. |
| R010-P1-C010 | Fedwire and similar systems used primarily for interinstitutional or business transfers are excluded EFT channels under § 1005.3(c)(3). | S003, § 3(c)(3), comments 1–3. Consumer Financial Protection Bureau | A subsequent ACH transfer to the consumer account can still be covered. | R/O; no full wire-transfer or UCC analysis. |
| R010-P1-C011 | The securities/commodities EFT exclusion depends on the transfer’s primary purpose and specified regulatory or book-entry conditions. | S003, § 3(c)(4), comments 1–3. Consumer Financial Protection Bureau | Ordinary purchases or cash withdrawals using a debit device against such an account are not automatically excluded. | R/O; separate from the credit exclusion in C021. |
| R010-P1-C012 | Specified automatic transfers within the same institution, including automatic fee entries, may be excluded from the EFT definition. | S003, § 3(c)(5), comments 1–2. Consumer Financial Protection Bureau | Agreement and institution initiation without a specific consumer request; prescribed account relationships. Affiliated institutions are not automatically the same institution. Compulsory-use and specified liability provisions remain preserved. | R/O; exclusion of a bookkeeping transfer does not authorize the underlying fee. |
| R010-P1-C013 | The telephone-transfer exclusion is conditional on absence of the specified telephone bill-payment or other written recurring-transfer plan. | S003, § 3(c)(6), comments 1–2. Consumer Financial Protection Bureau | A written service description can constitute a plan; infrequent use or separate requests do not necessarily remove coverage. | R/O; actual arrangement held. |
| R010-P1-C014 | The small-institution exemption is limited to preauthorized transfers, not every EFT or every overdraft fee. | S003, § 3(c)(7), comment 1. Consumer Financial Protection Bureau | Assets $100 million or less on the preceding December 31; specified phase-out one year after the end of the year in which assets exceed that figure; preserved provisions remain applicable. | R/O; sourced threshold, no entity calculation. |
| R010-P1-C015 | Comment 3(a)-3 supplies a U.S.-account/state-resident geographic framework, including certain U.S. offices of foreign banks. | S003, comment 3(a)-3; § 2(l). Consumer Financial Protection Bureau+1 | A foreign branch of a U.S. bank is not covered unless services connect to an account in a defined state; a particular transfer’s foreign location is not conclusive. | O/R; international and actual-location questions held. |
| R010-P1-C016 | A preauthorized EFT is authorized in advance to recur at substantially regular intervals without further consumer action. | S003, § 2(k), comment 2(k)-1. Consumer Financial Protection Bureau | Repeated separately initiated payments do not establish that definition; § 17 coding reliance remains separately relevant. | R/O; recurring classification unknown without facts. |
| R010-P1-C017 | “Prepaid account” is a defined category with specific inclusions and exclusions, not a synonym for every stored-value, gift, benefit, or digital-wallet product. | S003, § 2(b)(3) and comments. Consumer Financial Protection Bureau+1 | Payroll/government-benefit categories and specified prepaid/general-transaction products; exclusions include enumerated health, disaster, military closed-loop, gift, and needs-tested benefit arrangements. Checking/share-draft/NOW accounts are excluded from the residual prepaid category. | R/O; remote benefits, tax, and gift-card definitions not comprehensively closed. |
| R010-P1-C018 | A § 17 overdraft service involves the institution charging its consumer account for paying a transaction when funds are insufficient or unavailable. | S004, § 17(a). Consumer Financial Protection Bureau | Account held by that institution; paid transaction; fee or charge; no applicable § 17(a)(1)–(4) exclusion. | R; a negative ledger entry alone is insufficient classification evidence. |
| R010-P1-C019 | Payments pursuant to a credit line subject to Regulation Z are excluded from the § 17 overdraft-service definition. | S004, § 17(a)(1). Consumer Financial Protection Bureau | Includes transfers from a credit-card account, HELOC, or overdraft credit line if the specified predicate is met. | R; full credit-law consequences held. |
| R010-P1-C020 | A service transferring funds from another account held individually or jointly by the consumer is excluded from the § 17 overdraft-service definition. | S004, § 17(a)(2). Consumer Financial Protection Bureau | Actual transfer arrangement required; the definition does not simply equate every negative balance with such a transfer. | R; transfer charges and other laws not decided. |
| R010-P1-C021 | Specified securities/commodities credit exempt under Regulation Z § 1026.3(d) is excluded from § 17. | S004, § 17(a)(3), comment 17(a)-1; S007, § 1026.3(d), comment 1. Consumer Financial Protection Bureau+1 | Credit involving securities/commodities accounts extended by the specified SEC/CFTC-registered broker-dealer; a separate loan merely used to buy securities is not enough. | R/O; no registration or entity lookup. |
| R010-P1-C022 | The covered separate-credit-feature exclusion is specific to the qualifying feature accessible by a hybrid prepaid-credit card. | S004, § 17(a)(4); S007, § 1026.61(a)(1)–(2), (5). Consumer Financial Protection Bureau+2 | Card capability to access credit during transaction authorization, settlement, or completion, and provision by issuer, affiliate, or qualifying business partner. Noncovered separate credit can independently be subject to Reg Z. | R/O; no blanket exclusion of the entire prepaid account. |
| R010-P1-C023 | The prepaid negative-asset-balance exclusion requires the complete § 1026.61(a)(4) conditions. | S007, § 61(a)(4)(i)–(ii)(A)–(C) and comments. Consumer Financial Protection Bureau+2 | No access to issuer/affiliate covered separate credit; required decline policy/practice, with permitted $10 and unsettled-load cushions, which may coexist; no prohibited credit/negative-balance fees or higher fees because of credit. Actual collection costs are excepted only if otherwise lawful, and late fees are not such costs. Ordinary nonprohibited fees can themselves create a negative balance. | R/O; sourced legal cushion, no worked calculation; ordinary checking-account overdrafts cannot borrow this exception. |
| R010-P1-C024 | The business-partner definition has a specific exception for qualifying traditional-credit-card links. | S007, § 61(a)(5)(iii)(A)–(D), related comments. Consumer Financial Protection Bureau+2 | Traditional open-end non-home-secured card; separately signed/initialized request subject to stated pre-April-1-2019/pre-arrangement treatment; no prohibited conditioning; same prepaid terms/comparable load fees; same specified credit terms across linking and access methods. Network membership alone is insufficient to establish the arrangement. | R/O; definition only, no full credit-account compliance determination. |
| R010-P1-C025 | “Deposit advance,” “negative account,” and “setoff” labels do not establish a § 17 overdraft service or exclusion. | S004, § 17(a), comment 17(b)-2; S003, § 2(f), § 3(c)(5). Consumer Financial Protection Bureau+3 | Funding mechanism, paid transaction, credit agreement, fee causation, and any asserted debit/setoff authority must be distinguished. | I/U; no lending or setoff authority resolved. |
| R010-P1-C026 | A fee for returning an item unpaid is analytically different from a fee for paying an overdraft. | S004, § 17(a), (b)(1); S003, § 3(b)(3). Consumer Financial Protection Bureau+2 | Establish whether the item was actually paid or returned; do not classify by an ambiguous fee label. | R/I; § 17’s paid-overdraft prohibition does not establish NSF legality. |
| R010-P1-C027 | Electronic collection of a returned-item fee has its own authorization rule, distinct from overdraft opt-in. | S003, § 3(b)(3)(i)–(ii), comments 1–4. Consumer Financial Protection Bureau+1 | Notice plus proceeding with the underlying transaction can authorize that particular fee EFT; POS notice/copy conditions apply. Comment 1 excludes the account-holding FI’s own return/pay fee from this particular authorization provision. | R/O; this rule cannot be imported to infer § 17 opt-in from account use. |
| R010-P1-C028 | An ATM operator’s access/balance-inquiry fee is distinct from the account-holding institution’s overdraft fee. | S003, § 1005.16(a)–(d); S001, § 1693b(d)(3). Consumer Financial Protection Bureau+1 | § 16 operator does not hold the account; fee notice with amount must precede commitment, and the consumer must elect to continue. | R/S; continuing after an ATM fee screen does not itself establish separate overdraft consent. |
| Claim ID | Precise claim / area | Source and pinpoint | Trigger, conditions, exceptions | Status / limits |
|---|---|---|---|---|
| R010-P1-C029 | Four cumulative conditions govern charging for a covered paid ATM/one-time debit-card overdraft. | S004, § 17(b)(1)(i)–(iv). ecfr.gov | Notice, reasonable opportunity, affirmative consent, and confirmation with revocation information; historical timing in (c). | R; affirmative consent alone is insufficient. |
| R010-P1-C030 | The notice must be segregated, written or agreed electronic, clear, understandable, and retainable. | S004, § 17(b)(1)(i); S003, § 4(a); S010, 31667. ecfr.gov+2 | Oral notice does not satisfy the written/electronic disclosure requirement. | R/O/H; actual delivery and retained form unknown. |
| R010-P1-C031 | E-Sign § 7001(c) supplies a general consumer-electronic-record framework when law requires information in writing. | S008, § 7001(b), (c)(1)–(6). uscode.house.gov | Includes consent, prescribed information, access demonstration, and relevant exceptions when applicable. | S; not automatically imported into § 17. |
| R010-P1-C032 | The § 17 adopting explanation expressly treats electronic disclosures under that section as outside E-Sign’s consumer-consent requirements, while retaining clarity and retainability. | S009, footnote 32, 59041–59042, indices 8–9; current § 17(b)(1)(i), (iv). govinfo.gov+2 | Consumer agreement to electronic delivery remains required by § 17’s own text. | H explaining R; not a withdrawn CFPB circular; other documents’ E-Sign treatment held. |
| R010-P1-C033 | Reasonable opportunity includes reasonable means of communicating consent. | S004, comment 17(b)-4.i–iv. Consumer Financial Protection Bureau | Mail form, readily available telephone line, electronic choice/affirmation, and in-person form are examples; not a mandate to offer all four. | O; actual opportunity unknown. |
| R010-P1-C034 | Overdraft consent must be obtained separately from other consents and acknowledgments. | S004, comment 17(b)-6. Consumer Financial Protection Bureau | Includes separation from electronic-delivery consent. General preprinted account language and preselected opt-in boxes do not satisfy it. | O; actual consent evidence held. |
| R010-P1-C035 | Account use or acceptance of an access device cannot, without an authorized separate basis, be substituted for affirmative overdraft consent. | S004, § 17(b)(1)(iii), comments 17(b)-5–6; S003, § 2(a). Consumer Financial Protection Bureau+1 | Different statutory/regulatory forms of acceptance must not be conflated. | I from R/O; no implied-consent finding. |
| R010-P1-C036 | An institution may require an account-opening yes/no choice, but silence is not opt-in. | S004, comment 17(b)-5. Consumer Financial Protection Bureau | No selected box/signature means no opt-in; offered accounts must comply with (b)(2)–(3). | O; not permission to require the “yes” answer. |
| R010-P1-C037 | Confirmation must record the consent and include the right to revoke; a completed notice copy or acknowledgment letter can suffice. | S004, § 17(b)(1)(iv), comment 17(b)-7. Consumer Financial Protection Bureau | Writing, or electronic if agreed; oral confirmation does not satisfy the disclosure requirement. | R/O; actual content and delivery unknown. |
| R010-P1-C038 | The confirmation timing standard concerns transactions paid after confirmation is mailed or delivered. | S004, comment 17(b)-7; S010, 31667–31668. Consumer Financial Protection Bureau+1 | Comment recognizes compliance through reasonable procedures designed to ensure that timing. Consumer receipt is not required before a fee; later fee posting alone does not cure the payment-timing issue. | O/H; actual procedures and any error remain unresolved. |
| R010-P1-C039 | Covered overdraft fees may concern only overdrafts paid on or after receipt of affirmative consent, subject also to confirmation requirements. | S004, comment 17(c)-1. Consumer Financial Protection Bureau | Later consent does not retrospectively validate fees for earlier paid transactions. | O; event times unknown. |
| R010-P1-C040 | The opt-in notice must be substantially similar to A-9, include every applicable required item, and contain only specified or permitted information. | S004, § 17(d). Consumer Financial Protection Bureau | Specific § 17 rules govern permissible content and format. | R; no current form visual-comparison conclusion. |
| R010-P1-C041 | The notice must explain the service and relevant transaction types; other-transaction policies must not overshadow the opt-in right. | S004, § 17(d)(1), comment 17(d)-1. Consumer Financial Protection Bureau | Include discretion/possible decline explanation as applicable. | R/O; actual policy and accuracy unknown. |
| R010-P1-C042 | All applicable overdraft fees must be disclosed, including daily, sustained, and negative-balance fees; a variable fee requires its maximum. | S004, § 17(d)(2), comment 17(d)-2. Consumer Financial Protection Bureau | Amount can vary by number of overdrafts, overdraft size, or other factors. | R/O; no actual fee amount supplied or calculated. |
| R010-P1-C043 | The notice must disclose the maximum number of fees per day, or disclose that there is no limit. | S004, § 17(d)(3). Consumer Financial Protection Bureau | This is a disclosure requirement; it is not a national numerical fee cap or blanket permission under other law. | R/I. |
| R010-P1-C044 | The notice must explain the right to opt in and the means available for doing so. | S004, § 17(d)(4), comment 17(d)-3. Consumer Financial Protection Bureau | Methods must match what the institution actually offers. | R/O. |
| R010-P1-C045 | Offered linked-credit and same-institution account-transfer alternatives must be disclosed as applicable. | S004, § 17(d)(5), comment 17(d)-5. Consumer Financial Protection Bureau | Both offered means disclose both; one means disclose that one; neither means omit that reference. Other alternatives may be listed. | R/O; offering an alternative is not established here. |
| R010-P1-C046 | Section 17(d)(6) permits specified additional content concerning other-transaction choices, associated returned-item/merchant fees, revocation, and historical existing-account wording. | S004, § 17(d)(6). Consumer Financial Protection Bureau | Only as applicable; optional initial revocation wording does not eliminate mandatory revocation information in confirmation. | R. |
| R010-P1-C047 | A-9 can be tailored to offered consent methods; a tear-off form and a decline box are not invariably required. | S004, comments 17(d)-3–4. Consumer Financial Protection Bureau | Reasonable account-identification methods are permitted; no identifiers are entered in this pass. | O; no specific form approved. |
| R010-P1-C048 | Appendix A comments do not give blanket approval of institutional forms or every fee charged under them. | S005, Appendix A comments 1–3; S004, § 17(d). Consumer Financial Protection Bureau+1 | Accurate use of appropriate model language concerns proper disclosure form; specific § 17 content limits remain. | O/I; no individualized safe-harbor or liability decision. |
| R010-P1-C049 | Historical A-9 text was fully read; current A-9 pixels were not. | S005–S006; S011, 81021. federalreserve.gov+1 | The 2011 text-continuity statement supports historical comparison, not an assertion of current visual inspection. | H/U; current visual/read completeness remains partial. |
| R010-P1-C050 | Section 4’s general permission to combine disclosures does not override § 17’s specific segregation and content restrictions. | S003, § 4(b); S004, § 17(b)(1)(i), (d); S010, 31671. Consumer Financial Protection Bureau+2 | Other material may be in the same mailing while the opt-in notice remains segregated. | R/H/I. |
| R010-P1-C051 | Regulation E permits another disclosure language if English is available on request. | S003, § 4(a)(2), comment 4(a)-2. Consumer Financial Protection Bureau | Applies alongside the required content and clarity standards. | R/O; actual language/accessibility facts unknown. |
| R010-P1-C052 | For joint accounts, one set of required disclosures may be provided to any account holder. | S003, § 4(c)(2). Consumer Financial Protection Bureau | Separate § 17(e) governs whose consent or revocation binds the account. | R; disclosure delivery is not itself consent. |
| R010-P1-C053 | Institutions offering EFT services jointly may allocate compliance by agreement, but § 4(d)’s knowledge limitation expressly concerns §§ 7 and 8. | S003, § 4(d). Consumer Financial Protection Bureau | Does not itself create a § 17 exception for the account-holding institution. | R/I; actual actor allocation unknown. |
| Claim ID | Precise claim / area | Source and pinpoint | Trigger, conditions, exceptions | Status / limits |
|---|---|---|---|---|
| R010-P1-C054 | An institution cannot condition paying check/ACH/other overdrafts on ATM/debit opt-in or decline them because opt-in was refused. | S004, § 17(b)(2), comment 17(b)(2)-1. ecfr.gov+1 | Apply the same payment criteria consistently; this does not compel payment of every check or ACH item. | R/O. |
| R010-P1-C055 | Consumers declining opt-in must receive the same other account terms, conditions, and features. | S004, § 17(b)(3), comment 17(b)(3)-1. Consumer Financial Protection Bureau | Includes interest paid, fees, card capabilities, minimum balance, and online bill pay; exception is the protected overdraft service itself. | R/O. |
| R010-P1-C056 | Independently justified limited-feature accounts remain possible, but refusal to opt in cannot be used to divert an otherwise eligible consumer to them. | S004, comment 17(b)(3)-2. Consumer Financial Protection Bureau | Actual eligibility and account terms required. | O; no creditworthiness decision. |
| R010-P1-C057 | Without opt-in, the institution may pay the covered transaction but cannot charge for paying it. | S004, comment 17(b)-2. Consumer Financial Protection Bureau | Debit of principal is preserved only if permitted under other applicable law. | O; no debt-validity, collection, or setoff conclusion. |
| R010-P1-C058 | Opt-in does not guarantee authorization or payment of an overdraft. | S004, comment 17(b)-3. Consumer Financial Protection Bureau | Contractual or other obligations are not adjudicated here. | O. |
| R010-P1-C059 | Section 17(b) covers the relevant debit card only when issued by or on behalf of the account-holding institution. | S004, comment 17(b)-1.i. Consumer Financial Protection Bureau | Third-party issuance without the “on behalf of” relationship is outside that stated scope. | O; actual issuance/funding relationship unknown. |
| R010-P1-C060 | A one-time debit-card transaction can qualify whether conducted at POS, online, or by telephone. | S004, comment 17(b)-1.iii. Consumer Financial Protection Bureau | Channel location does not substitute for recurring/one-time classification. | O. |
| R010-P1-C061 | The coding reliance rule requires systems adapted to identify one-time versus recurring transactions. | S004, comment 17(b)-1.ii. Consumer Financial Protection Bureau | After that condition is met, merchant/institution/third-party coding may be relied upon. | O; coding accuracy, system adaptation, and actual reliance not established. |
| R010-P1-C062 | The fee prohibition applies to all otherwise covered institutions, including those with a general decline policy. | S004, comment 17(b)-1.iv. Consumer Financial Protection Bureau | An institution charging no fees for these paid overdrafts need not perform the § 17(b)(1)(i)–(iv) notice/opt-in process for that fee-free service. | O; no general policy-based fee exception. |
| R010-P1-C063 | Positive authorization followed by negative settlement does not excuse a covered fee where the required opt-in was absent. | S004, comment 17(b)-1.iv. Consumer Financial Protection Bureau | Commentary’s express example includes intervening transactions reducing funds before settlement. | O; other timing configurations and actual balances held. |
| R010-P1-C064 | With no opt-in, a fee based on negative-balance amount is prohibited when that balance is solely attributable to protected ATM/one-time debit transactions. | S004, comment 17(b)-8. Consumer Financial Protection Bureau | Requires fee classification and sole attribution. | O. |
| R010-P1-C065 | Section 17 does not prohibit that amount-based fee when the negative balance is wholly or partly attributable to a check, ACH, or another nonprotected transaction. | S004, comment 17(b)-8. Consumer Financial Protection Bureau | Does not validate a separate per-item fee for an unconsented protected card transaction. | O; other law/contract held. |
| R010-P1-C066 | With no opt-in, daily/sustained/negative-balance/similar fees are prohibited when the negative balance is solely attributable to protected transactions. | S004, comment 17(b)-9.i. Consumer Financial Protection Bureau | Fee substance and causation govern; a new fee label does not answer causation. | O/I. |
| R010-P1-C067 | Section 17 does not prohibit those ongoing fees where a negative balance is wholly or partly attributable to nonprotected transactions. | S004, comment 17(b)-9.i. Consumer Financial Protection Bureau | Subject to the timing rule in C068 and actual remaining balance attribution. | O; no all-law fee authorization. |
| R010-P1-C068 | For a mixed negative balance, the ongoing-fee timing anchor is when the nonprotected transaction was paid into overdraft. | S004, comment 17(b)-9.i, -9.ii.C. Consumer Financial Protection Bureau | An earlier protected card overdraft does not supply that start date. | O; contractual period, units, calendar, and events unknown. |
| R010-P1-C069 | The official mixed-balance examples depend on expressly stipulated posting and deposit-allocation assumptions. | S004, comment 17(b)-9.ii, examples A–C. Consumer Financial Protection Bureau | Later deposits can alter which debit component remains; associated fees matter in the examples. Their sample amounts and periods are not national legal thresholds. | O/I; no mandatory universal allocation method or actual calculation inferred. |
| R010-P1-C070 | A conservative alternative permits avoiding ongoing fees unless the outstanding negative balance is solely attributable to nonprotected transactions. | S004, comment 17(b)-9.iii. Consumer Financial Protection Bureau | This alternative avoids calculating allocation of partial deposits; it is an alternative, not the only required method. | O. |
| R010-P1-C071 | Any joint consumer’s affirmative consent binds the account; any joint consumer’s revocation likewise revokes account consent. | S004, § 17(e). Consumer Financial Protection Bureau | Joint relationship must actually exist. | R; no requirement that every joint holder separately opt in or revoke. |
| R010-P1-C072 | A consumer may opt in at any time and revoke at any time through the means made available for consent. | S004, § 17(f). Consumer Financial Protection Bureau | Opt-in follows the notice’s manner; revocation access must reflect available consent methods. | R. |
| R010-P1-C073 | Revocation must be implemented as soon as reasonably practicable. | S004, § 17(f). Consumer Financial Protection Bureau | The section supplies no fixed number of days for this implementation. | R; actual elapsed time and practicability unknown. |
| R010-P1-C074 | Revocation alone does not require reversal of fees assessed before implementation of the revocation request. | S004, comment 17(f)-1. Consumer Financial Protection Bureau | Does not establish that earlier fees were lawful or excuse unreasonable implementation delay. | O/I; separate grounds remain held. |
| R010-P1-C075 | Consent continues until revoked by the consumer or the institution terminates the service. | S004, § 17(g), comment 17(g)-1. Consumer Financial Protection Bureau | Termination is possible; excessive use is the comment’s example. | R/O; no actual termination or reconsent finding. |
| Claim ID | Precise claim / area | Source and pinpoint | Trigger, conditions, exceptions | Status / limits |
|---|---|---|---|---|
| R010-P1-C076 | The original final rule distinguished its effective date from its mandatory compliance date. | S009, 74 FR 59033, index 0. govinfo.gov | Effective January 19, 2010; mandatory compliance July 1, 2010, with the specific existing-account transition. | H; historical regulatory dates, not individual deadlines. |
| R010-P1-C077 | The 2010 clarification removed former (b)(4); its correction preserved the four subparagraph requirements by specifying amendment of the introductory text. | S010, 75 FR 31671–31672; correction 33681. govinfo.gov+1 | Both effective July 6, 2010. | H; former (b)(4) is not a current fee exception. |
| R010-P1-C078 | The 2011 rule recodified Regulation E into Part 1005 without new substantive obligations. | S011, 76 FR 81020–81021. govinfo.gov | Effective December 30, 2011; transfer of relevant rulemaking authority described as July 21, 2011. | H; current duties come from current text. |
| R010-P1-C079 | Accounts opened before July 1, 2010 were not permanently grandfathered out of opt-in. | S004, § 17(c)(1). Consumer Financial Protection Bureau | Covered fees assessed on or after August 15, 2010 require § 17(b)(1) compliance and affirmative consent. | R; opening date/fee facts unknown. |
| R010-P1-C080 | Accounts opened on or after July 1, 2010 require compliance and consent before covered fees are assessed. | S004, § 17(c)(2), comment 17(c)-1. Consumer Financial Protection Bureau | Also apply consent/payment and confirmation timing. | R/O; no actual event-date calculation. |
| R010-P1-C081 | Opt-in is not a waiver of all EFTA protections or every other fee limitation. | S002, § 1693l; S004, § 17. uscode.house.gov+1 | Statute preserves greater protection and expressly excepts a waiver given in settlement of a dispute or action. | S/I; no settlement, enforceability, or remedy decision. |
| R010-P1-C082 | The 2024 overdraft final rule originally stated an October 1, 2025 effective date. | S012, 89 FR 106768 and § V. govinfo.gov+1 | It was a final rule with a future effective date when issued. | H/D; that planned date is not treated as having activated the disapproved rule. |
| R010-P1-C083 | Public Law 119-10 disapproved the specifically identified 2024 final rule and gave it no force or effect. | S013, 139 Stat. 53, entire operative sentence. govinfo.gov | Approved May 9, 2025; identifies 89 FR 106768, December 30, 2024. | S; exact enacted effect read. |
| R010-P1-C084 | The disapproved rule’s added comment 17(a)-2 and new covered-overdraft framework cannot be used here as current requirements or exclusions. | S012, 106837, index 69; S013; current S004. govinfo.gov+2 | The preexisting Regulation Z-line exclusion still exists on its own terms. | D/R/I; no new fee cap inferred from the disapproved rule. |
| R010-P1-C085 | The CFPB resource page’s May 12 signing date conflicts with the enacted public law’s May 9 approval date. | S014 featured paragraph; S013 heading and approval line. Consumer Financial Protection Bureau+1 | This report uses May 9, 2025 for enactment/approval. | Verified source discrepancy; resource date not substituted for statute. |
| R010-P1-C086 | Circulars 2022-06 and 2024-05 are withdrawn guidance under the inspected official status materials. | S015 register and 90 FR 20084–20086; S016 publisher pages. Consumer Financial Protection Bureau+4 | Withdrawal applicable May 12, 2025. | W; historical analyses not current-rule substitutes. |
| R010-P1-C087 | Withdrawal of those circulars does not itself repeal the statute/regulation or affirmatively validate all fees discussed in them. | S015’s specified withdrawal action; S002–S004. federalregister.gov+2 | Distinguish guidance status from the continued text and scope of statutes/regulations. | I from S/R/W; other legal grounds remain open. |
| R010-P1-C088 | A stipulated compliant opt-in does not settle the full legality of an authorization-positive/settlement-negative fee. | S004, § 17 and comment 17(b)-1.iv; C081, C086–C087. Consumer Financial Protection Bureau+2 | Other applicable statutory, contract, disclosure, balance-method, and judicial questions need their own authority and facts. | U; no current broader liability theory asserted. |
| R010-P1-C089 | The generic rules cannot determine actual consent, causation, coding, contract compliance, liability, eligibility, or relief without facts not supplied and not searched. | Analytical limit of C002–C088; user scope. | All actual identity, account, balance, timing, agreement, and transaction facts remain blank. | U; no individual or class-action determination. |
| R010-P1-C090 | The checked current-resource labels and retrieved bodies support this bounded report, but do not certify all intervening legislation, publications, litigation, or current form pixels. | S001–S018 and failure log. ecfr.gov+2 | eCFR title currency through October 23; selected OLRC labels through October 20; older statutory recoveries; unread current image. | U / methodological qualification; no component or parent closure. |
These are anonymous legal branches, not accounts, consumers, institutions, or records. No names, identifiers, fee amounts, awards, individual dates, or filing deadlines are invented. “Evidence needed” identifies the type of unresolved fact, not a request or instruction to search for actual records.
| Example | Stipulated hypothetical facts | Section-specific result and remaining unknown | Evidence category needed | Adverse misclassification to avoid |
|---|---|---|---|---|
| E01 — No opt-in; paid one-time debit | All coverage predicates are stipulated; an account-holding FI pays a one-time debit-card overdraft; no affirmative consent exists. | § 17 prohibits a fee for paying it. Principal debit authority is separately conditional on applicable law. C018, C029, C057, C066. | Paid-item status, card relationship, channel, absence of consent, fee linkage. | Treating payment itself as consent; treating the fee prohibition as automatic principal forgiveness. |
| E02 — Affirmative opt-in; other conditions unknown | A separate affirmative choice is stipulated, but notice, opportunity, confirmation, and timing are unknown. | Fee authority under § 17 is not established merely by that choice. C029–C039. No actual violation or remedy is adjudicated. | Notice content/delivery, opportunity, confirmation, payment chronology, procedures. | Collapsing four cumulative requirements into “a consent box exists.” |
| E03 — Recurring classification uncertain | Debit-card payments recur in ordinary language, but advance authorization, further consumer action, coding, and adapted systems are unknown. | Classification remains unresolved. C016, C061. | Payment arrangement, initiation method, recurrence indicator, system adaptation/reliance. | Calling every repeated merchant payment recurring, or disregarding the commentary’s conditional coding rule. |
| E04 — Paid check or ACH | A transaction is stipulated to be a check or ACH debit, not an ATM/one-time card transaction; it is paid into overdraft. | The specific ATM/one-time-card opt-in prerequisite does not by itself prohibit the fee. C008–C009, C054, C065, C067. Other law and contract remain unknown. | Actual rail and paid status; fee type; governing contract. | Treating all EFTs as debit-card transactions; treating absence of this prohibition as universal legality. |
| E05 — No consent; other negative-balance source | No opt-in; the negative balance is stipulated to arise solely from a paid check or ACH transaction. | Comments 17(b)-8 and -9 do not prohibit the described balance-based/ongoing fee merely because there was no ATM/debit opt-in. C064–C068. | Complete causation and contract trigger. | Assuming every negative balance without opt-in is fee-free. |
| E06 — Revoked consent | A valid revocation has been implemented; a later covered one-time debit is paid. | The prior consent no longer supplies the opt-in predicate for a fee on that payment. C029, C072–C075. Earlier fees are not automatically reversed solely by revocation. | Revocation receipt, available methods, implementation, payment/fee events. | Treating revocation as retroactive cancellation of every prior fee, or as ineffective indefinitely. |
| E07 — Linked credit excluded | Payment is stipulated to occur pursuant to an overdraft line subject to Regulation Z. | Excluded from “overdraft service” under § 17(a)(1). C019. Credit agreement, APR, usury, origination, repayment, and other protections remain held. | Nature of credit line and funding mechanism. | Applying the § 17 opt-in rule as the complete law of the credit line. |
| E08 — Mixed transactions | No opt-in; protected card and check/ACH debits contribute to a continuing negative balance. | The protected card payment cannot carry its own unconsented overdraft fee. A separate ongoing fee requires the mixed-balance analysis and the nonprotected payment-date anchor. C064–C070. | Debit sequence, deposits/credits, allocation, associated fees, residual balance, fee period. | Letting one check validate all card fees; using the earliest card overdraft as the sustained-fee start. |
| E09 — Positive authorization; negative settlement; no opt-in | Covered one-time debit authorized when funds are believed sufficient; intervening activity leaves insufficient funds at settlement; no required opt-in. | The current comment expressly prohibits the fee for paying that transaction. C062–C063. | Authorization/settlement facts and consent status. | Treating a general decline policy or positive authorization as an exception. |
| E10 — Positive authorization; negative settlement; opt-in stipulated | All § 17 opt-in steps are stipulated satisfied; authorization and settlement balances differ. | This pass does not conclude that the fee is lawful or unlawful under all applicable law. C081, C086–C088. | Actual balance methodology, contract/disclosures, causation, independently applicable authority. | Using withdrawn Circular 2022-06 as current operative law, or treating its withdrawal as a universal permission. |
| E11 — Returned unpaid / NSF | The underlying item is stipulated to have been returned unpaid. | Classify the charge as a returned-item/NSF issue; the paid-overdraft fee rule alone does not decide it. A separate fee-collection EFT can implicate § 3(b)(3). C026–C027. | Returned/paid disposition; who assessed/collected the fee; collection method. | Calling an unpaid item a paid overdraft; confusing a merchant fee EFT with the FI’s own fee entry. |
| E12 — General agreement or account use only | The only stipulated acts are signing general account terms and using the account; no separate affirmative choice is stipulated. | Those acts do not establish the required separate opt-in. C034–C036. | Dedicated consent act and associated disclosure sequence. | Importing “use constitutes authorization” from a different rule. |
| E13 — Joint-holder revocation | A joint consumer revokes existing opt-in, with implementation stipulated. | Revocation operates for the account under § 17(e). C052, C071–C075. | Joint relationship and revocation chronology. | Requiring every joint holder to revoke, or treating one disclosure copy as every holder’s affirmative consent. |
| E14 — Prepaid negative balance | A product is called prepaid and has a negative asset balance; credit access, issuer relationships, decline policy, and fee conditions are unknown. | Neither § 17(a)(4) exclusion is established from the label or negative balance alone. C017, C022–C024. | Defined prepaid status; feature structure; issuer/affiliate/business-partner relationship; authorization policy; fee predicates. | Applying the prepaid exception to ordinary checking accounts or ignoring its no-prohibited-fee conditions. |
| E15 — ATM access fee | A non-account-holding ATM operator discloses its access fee and the consumer continues. | Analyze that operator fee under § 16; this does not itself establish § 17 overdraft consent to the account-holding FI. C028–C034. | Fee actor, fee purpose, screen/paper notice, separate overdraft process. | Treating acceptance of an ATM surcharge as overdraft opt-in. |
This is a blank analytical worksheet. It contains no actual or fictional identity entries. It does not authorize obtaining records, contacting anyone, submitting a form, or changing an account.
| Field | Generic question / document attribute | Entry | Claim / example links |
|---|---|---|---|
| W01 Product purpose | Is the asset account established primarily for personal/family/household or business purposes? | — | C002–C003 |
| W02 Account category | Checking/share draft/savings/prepaid/trust/other; which exact definition and exclusion governs? | — | C003, C017–C024 |
| W03 Actor role | Account holder, card issuer on its behalf, separate card issuer, ATM operator, merchant/payee, creditor, transfer-service actor? | — | C004–C006, C028, C053, C059 |
| W04 Geographic predicate | Account location and relevant statutory/regulatory residence/location predicates? | — | C015 |
| W05 EFT agreement | What generic agreement establishes EFT services, and which party’s agreement is relevant? | — | C006 |
| W06 Transaction rail/channel | ATM, one-time card, recurring card, ACH, check, converted check, wire, internal transfer, other? | — | C007–C016, C060–C061 |
| W07 Recurring classification | Advance authorization, substantially regular intervals, and further consumer action? | — | C016; E03 |
| W08 Coding reliance | Classification indicator, system adaptation, and basis for reliance on third-party coding? | — | C061; E03 |
| W09 Card relationship | Was the debit device issued by or on behalf of the account-holding institution? | — | C059 |
| W10 Payment disposition | Was the underlying item actually paid, declined, reversed, or returned unpaid? | — | C018, C026–C027; E11 |
| W11 Authorization/settlement | Relevant authorization and payment/settlement events; what does the operative rule actually answer? | — | C038–C039, C063, C088 |
| W12 Balance methodology | Ledger/available balance definitions, holds, unsettled items, posting order, reversals, and intervening credits? | — | C018, C063–C070, C088 |
| W13 Notice version/content | Service, transaction types, all fees, variable maxima, fee count, consent methods, offered alternatives, permitted additions? | — | C040–C047 |
| W14 Notice separation | Is the notice segregated from other information and the consent choice separate from other acknowledgments? | — | C030, C034, C050 |
| W15 Delivery/retention | Written or agreed electronic delivery; clear, understandable, retainable form; relevant language availability? | — | C030–C032, C051 |
| W16 Opportunity | What reasonable method and opportunity for affirmative choice were provided? | — | C033, C036 |
| W17 Consent act | What dedicated affirmative act occurred, and when was it received? | — | C034–C039 |
| W18 Confirmation | Written/agreed electronic confirmation, revocation statement, mailing/delivery event, reasonable procedures? | — | C037–C038 |
| W19 Joint relationship | Which joint-holder rule applies to disclosure, opt-in, or revocation? | — | C052, C071 |
| W20 Revocation | Method, receipt, implementation, practicability, and any later valid opt-in? | — | C072–C075 |
| W21 Fee classification | Per-item payment fee, balance-tier fee, daily/sustained fee, NSF, returned-deposit fee, transfer fee, credit charge, ATM surcharge, other? | — | C025–C028, C042–C043, C064–C070 |
| W22 Fee causation | Which paid transaction or remaining negative-balance components caused the particular fee? | — | C064–C069 |
| W23 Mixed-balance allocation | How do posting order, later deposits, associated fees, credits, and reversals affect residual attribution? | — | C068–C070; E08 |
| W24 Fee period and trigger | Disclosed contractual period; calendar or business-day units; starting event; continuing-balance condition; applicable exclusions? | — | C042, C068–C069 |
| W25 Linked arrangement | Reg Z line, own-account transfer, securities credit, qualifying prepaid feature, or another mechanism? | — | C019–C025 |
| W26 Other account terms | Same pricing/features and payment criteria regardless of opt-in; independent basis for any limited-feature product? | — | C054–C056 |
| W27 Unresolved governing facts | State/country/tribal status, contract terms, other legal limits, benefit protections, security/setoff, and other parent dimensions? | — | C081, C088–C090; parent holds |
Period versus calculation: W24 records a disclosed period and its trigger. It does not calculate a calendar date. No individual deadline or fee arithmetic was necessary or performed. The numerical amounts and timing assumptions embedded in official examples and A-9 were not converted into legal caps, mandatory grace periods, or actual obligations.
Answered means the generic rule is answered within the cited read bounds. It does not mean an actual transaction, component, state, or parent assignment has been accepted. Partial distinguishes source-retrieval limits from deliberately unavailable facts.
| Assigned subquestion / branch | Coverage | Claim / example links | Exact missing authority or facts | Next bounded permissible investigation |
|---|---|---|---|---|
| 1.a Enabling EFTA authority | Partial: substantive text read; currentness gap | C001; S001, S003, S011 | Current OLRC §§ 1693a–b bodies and complete later session-law lag audit. | Recover current official statutory text and check only relevant published amendments. |
| 1.b Consumer versus business account | Answered generically | C002–C003 | Actual primary purpose and account arrangement. | No actual-record inquiry authorized; maintain fact hold. |
| 1.c Bank/credit-union/other FI coverage | Answered generically | C004–C005, C053, C059 | Actual account-holder/issuer roles and any statutory excluded-person predicates. | Published definition clarification only; no institution/license search. |
| 1.d EFT-service agreement gateway | Answered generically | C006–C009 | Actual agreement, notice of third-party arrangement, transfer initiation. | Maintain fact hold. |
| 1.e Necessary EFT exclusions | Answered within relevant clauses | C008, C010–C014 | Actual rail, purpose, within-institution relationship, qualifying assets/plan. | Narrow public authority follow-up only if a specific legal ambiguity becomes material. |
| 1.f Geographic scope | Answered at federal gateway; broader scope held | C015 | Actual account location/residence; non-U.S. law. | No country-wide or international closure; separate bounded law review only. |
| 1.g Covered paid overdraft definition | Answered generically | C018 | Paid status, insufficient/unavailable funds, fee cause, account-holding actor. | Maintain fact hold. |
| 1.h Linked credit/own-account transfer/securities exclusions | Answered generically | C019–C021; E07 | Actual mechanism and agreement. | No credit-product or provider search. |
| 1.i Prepaid exclusion | Answered as conditional gate; product taxonomy partial | C017, C022–C024; E14 | Product facts; remote incorporated benefits/gift/tax definitions; historical prepaid-date chain. | Follow only a material published cross-reference; no full prepaid/credit closure. |
| 1.j Actual coding/classification | Unresolved facts | C016, C059–C061; E03 | Actual coding, adapted systems, reliance, recurring authorization. | No actual transaction search authorized. |
| 2.a Complete § 17 notice/consent/confirmation/revocation text | Answered; full section/comments read | C029–C047, C071–C080; S004 | Actual compliance facts only. | No additional generic authority needed for the stated text. |
| 2.b Segregated notice and separate choice | Answered generically | C030, C034–C036, C050; E12 | Actual presentation, dedicated choice, preselection. | Maintain fact hold. |
| 2.c Reasonable opportunity and methods | Answered generically | C033, C036, C044 | Actual opportunity and available methods. | Maintain fact hold. |
| 2.d Electronic delivery and retainability | Answered with authority-type distinction | C030–C032, C037 | Actual delivery agreement/retention; independent requirements for other documents. | Any further E-Sign work must identify the distinct legally required disclosure. |
| 2.e Confirmation timing | Answered generically | C037–C039; E02 | Mailing/delivery, consent receipt, transaction payment, reasonable procedures. | Maintain fact hold; no invented receipt deadline. |
| 2.f Complete required notice content | Answered generically | C040–C047 | Actual fees, service policies, alternatives, tailored text. | Compare only a permissible generic blank form if later needed. |
| 2.g Current A-9 body/image | Partial source retrieval | C049; S005–S006, S011 | Current image pixels and complete current image transcription not obtained. | Obtain readable official current form through permitted public tools; no access workaround. |
| 2.h Historical A-9 and current instructions | Answered within read bounds | C040–C049 | Historical-to-current visual comparison remains unverified. | Preserve distinction between historical parsed text and current image. |
| 2.i Revocation, joint holders, duration | Answered generically | C071–C075; E06, E13 | Actual joint status and event chronology. | Maintain fact hold. |
| 2.j Effective dates and existing accounts | Answered for § 17 transition/recodification | C076–C080 | Actual opening and payment dates. | No individual calendar calculation. |
| 3.a Complete fee prerequisite | Answered generically | C029, C057–C063 | Actual satisfaction of coverage and four conditions. | Maintain fact hold. |
| 3.b No conditioning of other overdrafts | Answered generically | C054 | Actual payment criteria and reason for decline. | No institutional practice investigation. |
| 3.c Same terms/features | Answered generically | C055–C056 | Actual comparative terms and independent eligibility. | No creditworthiness or account-eligibility decision. |
| 3.d Payment discretion versus fee authority | Answered generically | C057–C058; E01 | Applicable principal-debit law and contract remain unknown. | Preserve setoff/collection/contract holds. |
| 3.e Checks/ACH/recurring versus one-time card | Answered generically; classification facts unresolved | C008–C016, C059–C061; E03–E04 | Actual channel and recurring predicates. | Maintain fact hold. |
| 3.f Balance-amount fees | Answered generically | C064–C065; E05, E08 | Actual balance components and fee basis. | No ledger reconstruction authorized. |
| 3.g Daily/sustained/negative-balance fees | Answered generically | C066–C070 | Actual continuing attribution, contractual period, deposits and allocations. | Maintain fact hold; no universal period inferred. |
| 3.h Mixed-balance timing | Answered generically | C068–C070; E08 | Nonprotected payment date, period units, residual source. | Only generic further interpretation; no individual deadline. |
| 3.i Opt-in and other limits | Answered as limitation | C081, C088 | Broader governing law/contract and any settlement context. | Preserve parent holds. |
| 4.a Authorization-positive/settlement-negative without opt-in | Answered by current comment | C062–C063; E09 | Actual predicates, if any. | No withdrawn guidance needed. |
| 4.b Authorization-positive/settlement-negative with compliant opt-in | Unresolved broader legal basis | C088; E10 | Independently applicable law, balance/disclosure/contract facts. | If later necessary, inspect only material published primary authority; no docket query. |
| 4.c Withdrawn-guidance checks | Answered for every circular used for status | C086–C087; S015–S016 | No broader guidance-universe audit asserted. | Recheck official register only if another guidance item becomes necessary. |
| 4.d 2024/2025 final-rule disapproval | Answered for authority actually implicated | C082–C085; S012–S014 | Full unrelated provisions of disapproved rule not examined. | No need to revive its framework; retain exact statutory effect. |
| 4.e Paid versus returned/unpaid, NSF | Answered as distinction; broader law excluded | C026–C027; E11 | Actual disposition, actor and collection method; substantive NSF law. | Separate generic NSF component if later assigned. |
| 4.f Deposit advance, linked credit, setoff | Partial by intentional scope | C019–C025; E07 | Credit/security/setoff contracts and broader legal authority. | Preserve separate lending/setoff dimensions. |
| 4.g Published opinions/later litigation status | Excluded from conclusions; no case holding needed here | C088–C090 | No majority-opinion holding or later-history audit performed. | Only material published opinions if later strictly necessary; no case-record/docket-status query. |
| 5.a Blank audit worksheet | Delivered | W01–W27 | All entries intentionally blank. | No records request or identifier entry. |
| 5.b No-opt-in paid one-time branch | Delivered | E01; C029, C057 | Actual facts not supplied. | None within this published-source pass. |
| 5.c Affirmative consent, other conditions unknown | Delivered | E02; C029–C039 | Notice/opportunity/confirmation/timing facts. | Maintain hold. |
| 5.d Recurring classification branch | Delivered | E03; C016, C061 | Classification/coding/system facts. | Maintain hold. |
| 5.e Check or ACH branch | Delivered | E04; C008–C009, C054 | Channel and contract facts. | Maintain hold. |
| 5.f No consent, other negative source | Delivered | E05; C064–C068 | Causation and fee trigger. | Maintain hold. |
| 5.g Revoked-consent branch | Delivered | E06; C072–C075 | Receipt/implementation/payment chronology. | Maintain hold. |
| 5.h Linked-credit exclusion branch | Delivered | E07; C019 | Actual Reg Z credit arrangement. | Preserve credit-law holds. |
| 5.i Mixed-transactions branch | Delivered | E08; C064–C070 | Complete component allocation and timing. | Maintain hold. |
| 5.j Authorization/settlement branch | Delivered in two distinct forms | E09–E10; C063, C088 | With-opt-in broader legal basis remains unresolved. | No universal APSN conclusion. |
| Standards: current statutory/body/edition completeness | Partial | C090; failure log | Current bodies for identified statutes; complete intervening-publication audit. | Public primary-source recovery only. |
| Standards: UI/model provenance | Unverified beyond session identity | Opening provenance statement | Frontend and selector evidence unavailable. | No claim of unseen UI verification. |
| Parent/operational/publication acceptance | Excluded | Parent holds below | No authority or factual basis for acceptance/closure requested. | Preserve all holds; no operational action. |
| User assignment | Principal claims | Principal sources | Delivered examples / audit |
|---|---|---|---|
| 1. EFTA/Reg E consumer, account, institution, transfer coverage and exclusions | C001–C028, C059–C061 | S001, S003–S004, S007, S017 | E03–E04, E07, E11, E14–E15; W01–W12, W25 |
| 2. Complete notice, separate content/form, consent, confirmation, revocation, model, dates | C029–C053, C071–C080 | S003–S006, S008–S011 | E02, E06, E12–E13; W13–W20 |
| 3. Fee prohibition, conditioning, same terms, discretion, mixed-balance causation | C029, C054–C075, C081 | S002–S004, S010 | E01, E04–E08; W21–W26 |
| 4. Authorization/settlement, guidance withdrawal, repeal, unpaid/NSF/credit/setoff distinctions | C019–C028, C062–C063, C082–C090 | S003–S004, S007, S012–S017 | E07–E11, E14–E15; W10–W12, W21–W25 |
| 5. Blank audit and qualitative branches | C089–C090 and branch-specific claims above | Source-linked claim register | W01–W27 and E01–E15 |
| Standards and parent holds | C049, C081–C090 | Source table and read/failure log | Coverage table, self-check, parent holds |
| Log item | What was actually read | What was not represented as read |
|---|---|---|
| L01 — Current § 17 | Entire operative § 17(a)–(g), all embedded official interpretations, all three mixed-balance examples, and the alternative method. Annual § 17 PDF text also read in full. | No claim that the whole of Regulation E, all related regulations, or all annual-CFR pages were read. |
| L02 — Necessary gateway | Relevant § 2 definitions; complete § 3 coverage/exclusion text and relevant interpretations; complete § 4; complete § 16 for the ATM-operator distinction. | No full error-resolution, unauthorized-transfer-loss, benefits, remittance, gift-card, or state-law investigation. |
| L03 — Linked/prepaid exclusions | Necessary § 1026.3(d) and § 1026.61 definition/exception text, including negative-balance conditions and business-partner exception. | No comprehensive Regulation Z, APR, origination, security, repayment, or credit-account compliance review. |
| L04 — A-9 | Current heading/link and current § 17(d)/Appendix A instructions; complete parsed historical one-page A-9; 2011 statement of substantive continuity. | No current A-9 pixels seen. No claim of complete current-image transcription or visual comparison. |
| L05 — Final-rule dates and explanations | Necessary 2009 dates/electronic-delivery explanation; relevant 2010 clarification passages and complete correction; 2011 recodification/A-9 passage. | Not every page of each historical preamble. Historical provisions superseded by later clarification were not treated as current. |
| L06 — Disapproval | Complete Public Law 119-10; the 2024 rule’s stated effective date, necessary discussion, and complete added § 17(a)-2 comment; agency status paragraph. | Not the entire 78-page disapproved rule or a broader Congressional Review Act reissuance analysis. |
| L07 — Withdrawal | Official register, operative withdrawal discussion, relevant listed circulars, and publisher-page identification/scope passages. | No wholesale adoption of historical circular analyses or their cited cases; no assumption that a live URL means current guidance. |
| L08 — Statutes | Official 2024 §§ 1693a–b and § 5519 recovery bodies; current-labeled § 1693l and § 7001 bodies. | No claim that annual recovery text or a compilation header establishes complete current session-law status. |
| L09 — Images and screenshots | Parsed PDF text and image-link metadata only. | PDF text is not pixels. Placeholder image results and the failed A-9 screenshot were not counted as image inspection. |
| L10 — Discovery exclusions | Search results were used to locate permitted primary bodies. | Search snippets, headnotes, secondary reports, proposed-rule summaries, incidental case/entity results, and unopened prototype forms were not substantive foundations. No actual-case search was pursued. |
Repeated attempts at the same source are consolidated. These are retrieval gaps, not findings that a rule does not exist.
| Failure ID / source | Complete requested URLs or identified failed representation | Result and bounded consequence |
|---|---|---|
| F01 / S001 — Current § 1693a | https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1693a&num=0&edition=prelim ; https://uscode.house.gov/view.xhtml?req=%28title%3A15+section%3A1693a+edition%3Aprelim%29 ; https://uscode.house.gov/us/usc/119-134/t15/s1693a/ ; https://uscode.house.gov/us/usc/119-124/t15/s1693a/ ; https://uscode.house.gov/us/usc/119-121/t15/s1693a/ ; https://www.govinfo.gov/content/pkg/USCODE-2025-title15/html/USCODE-2025-title15-chap41-subchapVI-sec1693a.htm | Returned combinations of 404, page-not-found, disabled/inaccessible results. Recovered official 2024 body, S001. Current statutory lag remains unresolved. |
| F02 / S001 — Current § 1693b | https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1693b&num=0&edition=prelim ; https://uscode.house.gov/us/usc/119-134/t15/s1693b/ ; https://uscode.house.gov/us/usc/119-124/t15/s1693b/ ; https://uscode.house.gov/us/usc/119-121/t15/s1693b/ ; https://uscode.house.gov/us/usc/t15/s1693b/ ; https://www.govinfo.gov/content/pkg/USCODE-2025-title15/html/USCODE-2025-title15-chap41-subchapVI-sec1693b.htm ; https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapVI-sec1693b.htm | 500/inaccessible responses. Recovered official 2024 PDF body, S001. No inference of missing authority. |
| F03 / S001 — Current chapter fallback | https://uscode.house.gov/view.xhtml?edition=prelim&req=granuleid%3AUSC-prelim-title15-chapter41-subchapter6 | 404. Did not close statutory-currentness gap. |
| F04 / S002 — § 1693l path and repeat retrieval | https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1693l&num=0&edition=prelim ; https://uscode.house.gov/us/usc/119-134/t15/s1693l/ | Old path failed; modern body initially succeeded. One direct repeat failed; reopening the retrieved reference again returned the complete body. Recovered, with header limit preserved. |
| F05 / S017 — Current § 5519 | https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title12-section5519&num=0&edition=prelim ; https://uscode.house.gov/us/usc/119-134/t12/s5519/ ; https://uscode.house.gov/us/usc/t12/s5519/ | 404/inaccessible. Recovered 2024 official body, S017. No actual excluded-person determination. |
| F06 / S004 — Fixed annual § 17 URL | https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-sec1005-17.pdf | Fixed path inaccessible. Recovered complete 2026 § 17 through the Govinfo link URL in S004. |
| F07 / S005, S011, S018 — Current A-9 representation | Current PNG and appendix URLs in S005; embedded graphic in S011; full-part annual PDFs in S018. | Current image returned a placeholder; appendix extraction supplied heading but not full form body; PDF extraction omitted the graphic text. Current pixels/full-image transcription remain unverified. Historical parsed model recovered through S006. |
| F08 / S018 — Large 2026 CFR PDF | Both 2026 full-part URLs in S018. | Initial header/text success followed by targeted find/open timeouts. No full-part body-read claim. |
| F09 / S004, S006, S013 — Screenshots | § 17 PDF indices 0–2; public law index 0; historical A-9 index 0. | Earlier calls supplied image placeholders without inspectable image content. The historical A-9 screenshot returned an inability-to-resolve/screenshot-not-enabled error despite parsed PDF availability. No pixel-read claim. |
| F10 — Search-domain restriction | Search service reported a non-retryable robots restriction for https://www.congress.gov/ during generic legislative discovery. | No workaround attempted. The enacted public-law body was read from Govinfo, S013; no Congress.gov body is claimed read. |
| Check | Result |
|---|---|
| Independent primary-source investigation, without prior-report foundation | Performed. No unreviewed Library report or prior chat was used. |
| Complete focused § 1005.17 operative text and official interpretations | Read, including exclusions, all four conditions, notice content, conditioning, same terms, joint relationships, revocation, duration, and mixed-balance examples. |
| Statute versus regulation versus official interpretation versus guidance | Separated in source and claim statuses. |
| Current, historical, future-effective, disapproved, withdrawn, unknown | Separated. The 2024 rule’s planned effective date was not treated as operative; withdrawal was not treated as statutory repeal. |
| Current A-9 image read | Not achieved. Historical parsed text and current instructions are explicitly distinguished from current pixels. |
| Current statutory/edition/session-law audit | Partial. Identified current-body failures and older official recoveries are preserved. |
| Fee-causation reasoning | Qualified. Per-item, amount-based, ongoing, mixed-source, and returned-item branches are separated. |
| Authorization/settlement treatment | Bounded. No-opt-in example answered from the current comment; broader with-opt-in legality held. |
| Numerical integrity | No invented fees, awards, or deadlines. Regulatory thresholds stated are sourced; no individual arithmetic performed. |
| Actual-record, entity, identifier, or docket investigation | None conducted. |
| Individual liability, class eligibility, standing, remedies, filing advice | No determination made. |
| Component, state, parent, operations, or publication acceptance | None given. |
The following remain outside any closure or acceptance:
This report supplies the focused generic rules and expressly bounded conclusions for R010 PASS-01. It makes no operational, publication, component, state, or parent acceptance determination.
END R010 PASS-01
Captured cells with original header handling and explicitly labeled bounded correction overlays. Downloaded JSON retains original cells. Tables may contain source limitations, historical examples and identified corrections; the complete reading supplies context.
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
Source ID · Issuer/title and complete literal HTTPS URLs · Exact provisions; printed page / PDF index · 8 data rows
| Source ID | Issuer/title and complete literal HTTPS URLs | Exact provisions; printed page / PDF index | Version, effective predicate, status | Fresh-read extent and currentness limits |
|---|---|---|---|---|
| R010-P1-S001 | Congress; GPO, EFTA definitions and rulemaking authority. https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapVI-sec1693a.htm ; https://www.govinfo.gov/content/pkg/USCODE-2024-title15/pdf/USCODE-2024-title15-chap41-subchapVI-sec1693b.pdf | § 1693a operative definitions, especially (2), (6)–(11); § 1693b(a)–(e), particularly (a)–(d). PDF pp. 1645–1648, indices 0–3; its first page also contains the end of § 1693a. | Official 2024 Edition bodies. Statutory authority and definitions; not a representation of a fully audited October 2026 statutory edition. | Fresh, body read. Current OLRC versions of §§ 1693a–b failed; recovery was the official 2024 edition. 2025–2026 statutory lag remains open. COMMERCE AND TRADE +2 |
| R010-P1-S002 | Congress; OLRC, 15 USC 1693l—Waiver of rights. https://uscode.house.gov/us/usc/119-134/t15/s1693l/ | Entire operative paragraph and source credit; HTML, page/index N/A. | Header states laws in effect through PL 119-134, October 20, 2026. Applies to agreements waiving EFTA rights, with express exceptions. | Fresh, complete operative paragraph read. A direct repeat retrieval failed; reopening the previously retrieved reference recovered the body. Compilation label is not a session-law lag audit. uscode.house.gov |
| R010-P1-S003 | CFPB, Regulation E gateway, general disclosures, and ATM-operator distinction. https://www.consumerfinance.gov/rules-policy/regulations/1005/1/ ; https://www.consumerfinance.gov/rules-policy/regulations/1005/2/ ; https://www.consumerfinance.gov/rules-policy/regulations/1005/3/ ; https://www.consumerfinance.gov/rules-policy/regulations/1005/4/ ; https://www.consumerfinance.gov/rules-policy/regulations/1005/16/ | § 1(a)–(b); necessary § 2 definitions, including (a), (b), (e), (f), (h), (i), (k), (l), with relevant comments; § 3(a)–(c) and embedded interpretations; § 4(a)–(d) and comments; § 16(a)–(d). HTML, page/index N/A. | Agency pages labeled current regulation. Scope and exceptions depend on the account, actor, agreement, transfer, and product. | Fresh bodies read. Full § 2(b)(3) text was read, but its remote tax, benefits, and gift-card cross-references were not comprehensively followed. Full error-resolution, unauthorized-transfer, remittance, and broader disclosure regimes were not examined. Same Part 1005 as S004–S005, not independent corroboration. Consumer Financial Protection Bureau +6 |
| R010-P1-S004 | CFPB/OFR/GPO, 12 CFR 1005.17—Requirements for overdraft services, and official interpretations. https://www.consumerfinance.gov/rules-policy/regulations/1005/17/ ; https://www.ecfr.gov/current/title-12/chapter-X/part-1005/subpart-A/section-1005.17 ; https://www.govinfo.gov/link/cfr/12/1005?link-type=pdf§ionnum=17&year=mostrecent | Entire § 17(a)–(g) and all embedded § 17 official comments, including 17(b)-9.ii.A–C and -9.iii. Annual PDF pp. 204–206, indices 0–2, § 17 only. | CFPB current label; latest eCFR read displayed Title 12 through 2026-10-23 and described eCFR as authoritative but unofficial. PDF resolves to 1-1-26 Edition, source note 76 FR 81023, amended 81 FR 84328. Historical § 17(c) triggers remain printed in current text. | Fresh, complete necessary operative section and interpretations read. Annual PDF parsed text read; screenshots did not yield inspectable pixels. No full post-October-23 publication-lag audit. These are reproductions of one regulatory instrument. ecfr.gov +5 |
| R010-P1-S005 | CFPB/OFR, Current Appendix A, Model A-9, and Appendix A interpretations. https://www.consumerfinance.gov/rules-policy/regulations/1005/a/ ; https://www.consumerfinance.gov/rules-policy/regulations/1005/interp-a/ ; https://files.consumerfinance.gov/f/ER27DE11.000.png ; https://www.ecfr.gov/current/title-12/chapter-X/part-1005/appendix-Appendix%20A%20to%20Part%201005 | A-9 heading and linked graphic; Appendix A comments 1–3; complete A-9-specific instructions in § 17(d) and comments 17(d)-1–5, S004. HTML/PNG; printed page/index N/A. | Current agency appendix presentation; eCFR appendix currency label through 2026-10-23. | Fresh, partial form read. Current instructions and appendix comments read. Current graphic returned an image placeholder, not visible pixels or complete extracted form text. Current visual form comparison remains unresolved. Consumer Financial Protection Bureau +3 |
| R010-P1-S006 | Federal Reserve, generic Model A-9 distributed with the 2009 final rule. https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20091112a3.pdf ; discovery page: https://www.federalreserve.gov/newsevents/pressreleases/bcreg20091112a.htm | Complete one-page form body, parsed lines 0–35; unpaginated, PDF index 0. | Historical November 12, 2009 distribution. S011 expressly describes the 2011 A-9 as substantively identical except “website” spelling. | Fresh, complete parsed historical form text read; pixels not read. PDF metadata labels it an opt-out form, but the actual body and publisher link identify the relevant A-9 consent form; metadata was not substituted for the body. Illustrative fees and periods are not legal limits. Press release used for discovery, not operative dates. federalreserve.gov +2 |
| R010-P1-S007 | CFPB, Regulation Z cross-references necessary to § 17(a). https://www.consumerfinance.gov/rules-policy/regulations/1026/3/ ; https://www.consumerfinance.gov/rules-policy/regulations/1026/61/ | § 1026.3(d), comment 3(d)-1; § 1026.61(a)(1)–(5), especially (a)(2), (a)(4), (a)(5)(iii)(D), and necessary embedded comments. HTML, page/index N/A. | Agency current-regulation presentation. Applied only to the exclusions expressly incorporated by § 17(a). | Fresh, necessary definition/exception bodies read. Full Reg Z lending, APR, origination, repayment, security, and remedy regimes remain held. Historical prepaid-effective-date chain was not comprehensively audited; no historical product application is made. Consumer Financial Protection Bureau +7 |
| R010-P1-S008 | Congress; OLRC, 15 USC 7001—E-Sign general rule. https://uscode.house.gov/us/usc/119-134/t15/s7001/ | § 7001(a), (b), (c)(1)–(6); additional text and effective-date notes also returned. HTML, page/index N/A. | Header through PL 119-134, October 20, 2026. § 7001(c) concerns information legally required in writing; see S009 for the § 17-specific adopting explanation. | Fresh, complete relevant subsections read. Used to distinguish the general statute from the special overdraft disclosure treatment, not to create an extra § 17 consent condition. Compilation-lag qualification retained. uscode.house.gov |
Source ID · Issuer/title and complete literal HTTPS URLs · Exact provisions; printed page / PDF index · 10 data rows
| Source ID | Issuer/title and complete literal HTTPS URLs | Exact provisions; printed page / PDF index | Version, effective predicate, status | Fresh-read extent and currentness limits |
|---|---|---|---|---|
| R010-P1-S009 | Federal Reserve, Electronic Fund Transfers—2009 final rule and official staff commentary. https://www.federalregister.gov/documents/2009/11/17/E9-27474/electronic-fund-transfers ; https://www.govinfo.gov/content/pkg/FR-2009-11-17/pdf/E9-27474.pdf | 74 FR 59033–59056, 24-page PDF, indices 0–23. Relevant read: dates at 59033 / 0; notice discussion and complete footnote 32 at 59041–59042 / 8–9; confirmation discussion 59043 / 10. | Published 2009-11-17; effective 2010-01-19; mandatory compliance 2010-07-01, with existing-account treatment in § 17(c). Historical adopting rule; subsequently clarified and recodified. | Fresh, selected necessary body passages read, not a claimed full 24-page read. Official PDF verified the electronic-delivery explanation. Original former § 205.17(b)(4) is not used as current text. govinfo.gov +3 |
| R010-P1-S010 | Federal Reserve, 2010 clarification and correction. https://www.federalregister.gov/documents/2010/06/04/2010-13280/electronic-fund-transfers ; https://www.govinfo.gov/content/pkg/FR-2010-06-04/pdf/2010-13280.pdf ; https://www.federalregister.gov/documents/2010/06/15/2010-14353/electronic-fund-transfers ; https://www.govinfo.gov/content/pkg/FR-2010-06-15/pdf/2010-14353.pdf | 75 FR 31665–31673, indices 0–8: scope/confirmation discussion, balance-fee discussion, content instructions, and amendatory text. Correction at 33681 / index 0, operative correction fully read. | Both effective 2010-07-06. Clarification removes former (b)(4); correction specifies revision of the (b)(1) introductory text, preserving the subparagraph requirements. | Fresh, selected relevant clarification passages and complete correction read. Current complete comments are independently read as the same regulation in S004. Historical PDF’s final page also contains another rule, which is not adopted as a foundation. federalregister.gov +4 |
| R010-P1-S011 | CFPB, Electronic Fund Transfers—2011 recodification. https://www.govinfo.gov/content/pkg/FR-2011-12-27/pdf/2011-31725.pdf | 76 FR 81020–81058, 39 pages. Necessary read at 81020–81021 / indices 0–1: transfer, recodification, effective date, A-9 change. | Interim final rule; effective 2011-12-30. Rulemaking transfer described as effective 2011-07-21. No new substantive obligations asserted by this recodification. | Fresh, selected body read. A-9 continuity passage fully read. The embedded A-9 graphic was not visually inspected; its exact graphic-page location is not asserted. Not merely a proposal. govinfo.gov |
| R010-P1-S012 | CFPB, Overdraft Lending: Very Large Financial Institutions. https://www.federalregister.gov/documents/2024/12/30/2024-29699/overdraft-lending-very-large-financial-institutions ; https://www.govinfo.gov/content/pkg/FR-2024-12-30/pdf/2024-29699.pdf | 89 FR 106768–106845, 78 pages. Dates 106768 / 0; § IV discussion and § V timing 106816 / 48; complete added comment 17(a)-2 at 106837 / 69. | Published 2024-12-30, stated effective 2025-10-01; disapproved before that date by S013. | Fresh, selected provisions read, not all 78 pages. Used only to identify the exact disapproved change and original trigger. No proposed or disapproved framework is used as current authority. govinfo.gov +2 |
| R010-P1-S013 | Congress, Public Law 119-10, S.J. Res. 18. https://www.govinfo.gov/content/pkg/PLAW-119publ10/pdf/PLAW-119publ10.pdf | 139 Stat. 53 / PDF index 0, entire one-page law. | Approved 2025-05-09. Disapproves the specifically named 89 FR 106768 final rule and gives it no force or effect. | Fresh, complete parsed law read. Screenshot yielded no inspectable pixels; the text body was fully available. No docket or litigation-status inference. govinfo.gov |
| R010-P1-S014 | CFPB, Overdraft Lending compliance resource/status page. https://www.consumerfinance.gov/compliance/compliance-resources/deposit-accounts-resources/overdraft-lending-very-large-financial-institutions/ | “Featured topic” paragraph; HTML, page/index N/A. | Page modified 2025-07-01. Says the final rule has no force/effect and remaining Reg E/Z remain unchanged. | Fresh status paragraph read. Its statement that signing occurred May 12 conflicts with S013’s May 9 approval date. Public-law date controls this report. Resource label does not replace operative text. Consumer Financial Protection Bureau |
| R010-P1-S015 | CFPB, Withdrawn Guidance register and withdrawal notice. https://www.consumerfinance.gov/compliance/guidance/withdrawn-guidance/ ; https://www.federalregister.gov/documents/2025/05/12/2025-08286/interpretive-rules-policy-statements-and-advisory-opinions-withdrawal ; https://www.govinfo.gov/content/pkg/FR-2025-05-12/pdf/2025-08286.pdf | Register’s Circulars & Supervisory Guidance entries for 2024-05 and 2022-06; notice parts I–III and relevant entries. 90 FR 20084–20087, indices 0–3; applicability at 20084 / 0, operative withdrawal discussion 20085 / 1, relevant list 20086 / 2. | Withdrawals applicable 2025-05-12. Register last-modified label 2026-07-22. | Fresh register and necessary notice bodies read. Register and notice are one publisher’s status chain, not independent corroboration. Withdrawal is not treated as statutory repeal or a universal fee validation. Consumer Financial Protection Bureau +3 |
| R010-P1-S016 | CFPB, historical circular publisher pages. https://www.consumerfinance.gov/compliance/circulars/consumer-financial-protection-circular-2022-06-unanticipated-overdraft-fee-assessment-practices/ ; https://www.consumerfinance.gov/compliance/circulars/consumer-financial-protection-circular-2024-05/ | Titles, questions/answers and relevant scope passages; HTML, page/index N/A. Register cites 87 FR 66935, Nov. 7, 2022, and 89 FR 80075, Oct. 2, 2024. | Withdrawn, as verified against S015. | Fresh, limited publisher-page read and status check. Not a full read of every cited authority. No historical enforcement/evidence theory is adopted as current operative law. Continued page availability is not currentness. Consumer Financial Protection Bureau +4 |
| R010-P1-S017 | Congress; GPO, 12 USC 5519—Exclusion for auto dealers. https://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap53-subchapV-partB-sec5519.htm | Entire operative (a)–(f), particularly jurisdictional exclusion, exceptions, preserved authorities, and definitions. HTML, page/index N/A. | Official 2024 Edition recovery. Cross-reference in §§ 1005.2(i), 1005.3(a), and 1693b(a)(2). | Fresh body read. Current OLRC retrieval failed. No dealer, license, entity, or business-line classification was attempted. Statutory lag remains held. BANKS AND BANKING |
| R010-P1-S018 | GPO, full Part 1005 recovery attempts. https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1005.pdf ; https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-part1005.pdf ; https://www.govinfo.gov/link/cfr/12/1005?link-type=pdf&year=mostrecent | 2025 A-9 location: printed 245 / index 60, heading but missing form-body extraction. 2026 full-part header/initial text retrieved; subsequent targeted retrievals timed out. | Annual editions, not October 2026 complete currency guarantees. | Fresh, partial/discovery/failure. No whole-part read claimed. Used to attempt form/text recovery, not independent authority beyond S003–S005. |
Claim ID · Precise claim / area · Source and pinpoint · 28 data rows
| Claim ID | Precise claim / area | Source and pinpoint | Trigger, conditions, exceptions | Status / limits |
|---|---|---|---|---|
| R010-P1-C001 | EFTA supplies rulemaking authority for Regulation E; the specific overdraft opt-in conditions are in § 1005.17. | S001, § 1693b(a)–(c); S003, § 1005.1(a); S011, 81021. govinfo.gov +2 | Bureau authority has statutory reservations, including Board authority described in § 1693b(a)(2). | S/R; current statutory-body gap disclosed. |
| R010-P1-C002 | The relevant consumer/account gateway requires a natural person and an asset account established primarily for personal, family, or household purposes. | S001, § 1693a(2), (6); S003, §§ 1005.2(b)(1), (e). COMMERCE AND TRADE +2 | Business-purpose accounts do not qualify merely because a natural person owns or uses them. | S/R; actual purpose unknown. |
| R010-P1-C003 | The account definition excludes incidental credit balances in open-end credit plans and accounts held under bona fide trust agreements. | S001, § 1693a(2); S003, § 1005.2(b)(1)–(2), comments 2(b)(2). COMMERCE AND TRADE +1 | Trust status depends on the actual arrangement and governing law; the comment supplies additional excluded-account examples. | S/R/O; no actual account classification. |
| R010-P1-C004 | Banks, savings associations, and credit unions are included financial-institution classes; the regulation also includes specified other account holders and access-device issuers. | S001, § 1693a(9); S003, § 1005.2(i). COMMERCE AND TRADE +1 | Direct/indirect holding, or access-device issuance plus agreement to provide EFT services, must fit the definition; statutory excluded-person clause remains. | S/R; no named institution or charter inquiry. |
| R010-P1-C005 | The CFPA § 1029 cross-reference is a conditional jurisdictional exclusion, not a blanket statement that all auto-related activity is outside federal EFT law. | S017, § 5519(a)–(c), (f); S001, § 1693b(a)(2). BANKS AND BANKING +1 | Predominant vehicle-dealer activity; exceptions for specified real-property services, retained direct retail credit/leases, and unrelated consumer financial services; other agency authorities preserved. | S; 2024 body, later statutory lag and all entity facts held. |
| R010-P1-C006 | Regulation E account coverage requires an EFT-service agreement of the kind described in comment 3(a)-1. | S003, § 1005.3(a), comments 3(a)-1–2. Consumer Financial Protection Bureau | Consumer–FI agreement, or consumer–third-party agreement with FI notice and transfers begun. ACH membership alone is insufficient. | R/O; actual agreement unknown. |
| R010-P1-C007 | EFT coverage includes qualifying ATM, POS, debit-card, ACH, direct-deposit/withdrawal, telephone, and computer-initiated transfers. | S003, § 1005.3(b)(1), comment 3(b)(1)-1. Consumer Financial Protection Bureau | Must instruct debit/credit of a covered consumer account and survive applicable exclusions. | R/O; channel labels require facts. |
| R010-P1-C008 | A check converted into an ACH EFT differs from a check collected or re-presented electronically as a check. | S003, § 1005.3(b)(2), comments 3(b)(1)-1.v and 3(c)(1)-1–2. Consumer Financial Protection Bureau +1 | Using check information to initiate ACH can be EFT; electronic re-presentment of the original check remains within the check exclusion. | R/O; no transaction coding assumed. |
| R010-P1-C009 | Being an EFT does not by itself bring a transfer within the ATM/one-time debit-card fee prohibition. | S003, § 1005.3(b); S004, § 1005.17(b)(1). Consumer Financial Protection Bureau +1 | The specific transaction must fit § 17’s channel and service conditions. | I from R; one-time ACH is not automatically one-time debit card. |
| R010-P1-C010 | Fedwire and similar systems used primarily for interinstitutional or business transfers are excluded EFT channels under § 1005.3(c)(3). | S003, § 3(c)(3), comments 1–3. Consumer Financial Protection Bureau | A subsequent ACH transfer to the consumer account can still be covered. | R/O; no full wire-transfer or UCC analysis. |
| R010-P1-C011 | The securities/commodities EFT exclusion depends on the transfer’s primary purpose and specified regulatory or book-entry conditions. | S003, § 3(c)(4), comments 1–3. Consumer Financial Protection Bureau | Ordinary purchases or cash withdrawals using a debit device against such an account are not automatically excluded. | R/O; separate from the credit exclusion in C021. |
| R010-P1-C012 | Specified automatic transfers within the same institution, including automatic fee entries, may be excluded from the EFT definition. | S003, § 3(c)(5), comments 1–2. Consumer Financial Protection Bureau | Agreement and institution initiation without a specific consumer request; prescribed account relationships. Affiliated institutions are not automatically the same institution. Compulsory-use and specified liability provisions remain preserved. | R/O; exclusion of a bookkeeping transfer does not authorize the underlying fee. |
| R010-P1-C013 | The telephone-transfer exclusion is conditional on absence of the specified telephone bill-payment or other written recurring-transfer plan. | S003, § 3(c)(6), comments 1–2. Consumer Financial Protection Bureau | A written service description can constitute a plan; infrequent use or separate requests do not necessarily remove coverage. | R/O; actual arrangement held. |
| R010-P1-C014 | The small-institution exemption is limited to preauthorized transfers, not every EFT or every overdraft fee. | S003, § 3(c)(7), comment 1. Consumer Financial Protection Bureau | Assets $100 million or less on the preceding December 31; specified phase-out one year after the end of the year in which assets exceed that figure; preserved provisions remain applicable. | R/O; sourced threshold, no entity calculation. |
| R010-P1-C015 | Comment 3(a)-3 supplies a U.S.-account/state-resident geographic framework, including certain U.S. offices of foreign banks. | S003, comment 3(a)-3; § 2(l). Consumer Financial Protection Bureau +1 | A foreign branch of a U.S. bank is not covered unless services connect to an account in a defined state; a particular transfer’s foreign location is not conclusive. | O/R; international and actual-location questions held. |
| R010-P1-C016 | A preauthorized EFT is authorized in advance to recur at substantially regular intervals without further consumer action. | S003, § 2(k), comment 2(k)-1. Consumer Financial Protection Bureau | Repeated separately initiated payments do not establish that definition; § 17 coding reliance remains separately relevant. | R/O; recurring classification unknown without facts. |
| R010-P1-C017 | “Prepaid account” is a defined category with specific inclusions and exclusions, not a synonym for every stored-value, gift, benefit, or digital-wallet product. | S003, § 2(b)(3) and comments. Consumer Financial Protection Bureau +1 | Payroll/government-benefit categories and specified prepaid/general-transaction products; exclusions include enumerated health, disaster, military closed-loop, gift, and needs-tested benefit arrangements. Checking/share-draft/NOW accounts are excluded from the residual prepaid category. | R/O; remote benefits, tax, and gift-card definitions not comprehensively closed. |
| R010-P1-C018 | A § 17 overdraft service involves the institution charging its consumer account for paying a transaction when funds are insufficient or unavailable. | S004, § 17(a). Consumer Financial Protection Bureau | Account held by that institution; paid transaction; fee or charge; no applicable § 17(a)(1)–(4) exclusion. | R; a negative ledger entry alone is insufficient classification evidence. |
| R010-P1-C019 | Payments pursuant to a credit line subject to Regulation Z are excluded from the § 17 overdraft-service definition. | S004, § 17(a)(1). Consumer Financial Protection Bureau | Includes transfers from a credit-card account, HELOC, or overdraft credit line if the specified predicate is met. | R; full credit-law consequences held. |
| R010-P1-C020 | A service transferring funds from another account held individually or jointly by the consumer is excluded from the § 17 overdraft-service definition. | S004, § 17(a)(2). Consumer Financial Protection Bureau | Actual transfer arrangement required; the definition does not simply equate every negative balance with such a transfer. | R; transfer charges and other laws not decided. |
| R010-P1-C021 | Specified securities/commodities credit exempt under Regulation Z § 1026.3(d) is excluded from § 17. | S004, § 17(a)(3), comment 17(a)-1; S007, § 1026.3(d), comment 1. Consumer Financial Protection Bureau +1 | Credit involving securities/commodities accounts extended by the specified SEC/CFTC-registered broker-dealer; a separate loan merely used to buy securities is not enough. | R/O; no registration or entity lookup. |
| R010-P1-C022 | The covered separate-credit-feature exclusion is specific to the qualifying feature accessible by a hybrid prepaid-credit card. | S004, § 17(a)(4); S007, § 1026.61(a)(1)–(2), (5). Consumer Financial Protection Bureau +2 | Card capability to access credit during transaction authorization, settlement, or completion, and provision by issuer, affiliate, or qualifying business partner. Noncovered separate credit can independently be subject to Reg Z. | R/O; no blanket exclusion of the entire prepaid account. |
| R010-P1-C023 | The prepaid negative-asset-balance exclusion requires the complete § 1026.61(a)(4) conditions. | S007, § 61(a)(4)(i)–(ii)(A)–(C) and comments. Consumer Financial Protection Bureau +2 | No access to issuer/affiliate covered separate credit; required decline policy/practice, with permitted $10 and unsettled-load cushions, which may coexist; no prohibited credit/negative-balance fees or higher fees because of credit. Actual collection costs are excepted only if otherwise lawful, and late fees are not such costs. Ordinary nonprohibited fees can themselves create a negative balance. | R/O; sourced legal cushion, no worked calculation; ordinary checking-account overdrafts cannot borrow this exception. |
| R010-P1-C024 | The business-partner definition has a specific exception for qualifying traditional-credit-card links. | S007, § 61(a)(5)(iii)(A)–(D), related comments. Consumer Financial Protection Bureau +2 | Traditional open-end non-home-secured card; separately signed/initialized request subject to stated pre-April-1-2019/pre-arrangement treatment; no prohibited conditioning; same prepaid terms/comparable load fees; same specified credit terms across linking and access methods. Network membership alone is insufficient to establish the arrangement. | R/O; definition only, no full credit-account compliance determination. |
| R010-P1-C025 | “Deposit advance,” “negative account,” and “setoff” labels do not establish a § 17 overdraft service or exclusion. | S004, § 17(a), comment 17(b)-2; S003, § 2(f), § 3(c)(5). Consumer Financial Protection Bureau +3 | Funding mechanism, paid transaction, credit agreement, fee causation, and any asserted debit/setoff authority must be distinguished. | I/U; no lending or setoff authority resolved. |
| R010-P1-C026 | A fee for returning an item unpaid is analytically different from a fee for paying an overdraft. | S004, § 17(a), (b)(1); S003, § 3(b)(3). Consumer Financial Protection Bureau +2 | Establish whether the item was actually paid or returned; do not classify by an ambiguous fee label. | R/I; § 17’s paid-overdraft prohibition does not establish NSF legality. |
| R010-P1-C027 | Electronic collection of a returned-item fee has its own authorization rule, distinct from overdraft opt-in. | S003, § 3(b)(3)(i)–(ii), comments 1–4. Consumer Financial Protection Bureau +1 | Notice plus proceeding with the underlying transaction can authorize that particular fee EFT; POS notice/copy conditions apply. Comment 1 excludes the account-holding FI’s own return/pay fee from this particular authorization provision. | R/O; this rule cannot be imported to infer § 17 opt-in from account use. |
| R010-P1-C028 | An ATM operator’s access/balance-inquiry fee is distinct from the account-holding institution’s overdraft fee. | S003, § 1005.16(a)–(d); S001, § 1693b(d)(3). Consumer Financial Protection Bureau +1 | § 16 operator does not hold the account; fee notice with amount must precede commitment, and the consumer must elect to continue. | R/S; continuing after an ATM fee screen does not itself establish separate overdraft consent. |
Claim ID · Precise claim / area · Source and pinpoint · 25 data rows
| Claim ID | Precise claim / area | Source and pinpoint | Trigger, conditions, exceptions | Status / limits |
|---|---|---|---|---|
| R010-P1-C029 | Four cumulative conditions govern charging for a covered paid ATM/one-time debit-card overdraft. | S004, § 17(b)(1)(i)–(iv). ecfr.gov | Notice, reasonable opportunity, affirmative consent, and confirmation with revocation information; historical timing in (c). | R; affirmative consent alone is insufficient. |
| R010-P1-C030 | The notice must be segregated, written or agreed electronic, clear, understandable, and retainable. | S004, § 17(b)(1)(i); S003, § 4(a); S010, 31667. ecfr.gov +2 | Oral notice does not satisfy the written/electronic disclosure requirement. | R/O/H; actual delivery and retained form unknown. |
| R010-P1-C031 | E-Sign § 7001(c) supplies a general consumer-electronic-record framework when law requires information in writing. | S008, § 7001(b), (c)(1)–(6). uscode.house.gov | Includes consent, prescribed information, access demonstration, and relevant exceptions when applicable. | S; not automatically imported into § 17. |
| R010-P1-C032 | The § 17 adopting explanation expressly treats electronic disclosures under that section as outside E-Sign’s consumer-consent requirements, while retaining clarity and retainability. | S009, footnote 32, 59041–59042, indices 8–9; current § 17(b)(1)(i), (iv). govinfo.gov +2 | Consumer agreement to electronic delivery remains required by § 17’s own text. | H explaining R; not a withdrawn CFPB circular; other documents’ E-Sign treatment held. |
| R010-P1-C033 | Reasonable opportunity includes reasonable means of communicating consent. | S004, comment 17(b)-4.i–iv. Consumer Financial Protection Bureau | Mail form, readily available telephone line, electronic choice/affirmation, and in-person form are examples; not a mandate to offer all four. | O; actual opportunity unknown. |
| R010-P1-C034 | Overdraft consent must be obtained separately from other consents and acknowledgments. | S004, comment 17(b)-6. Consumer Financial Protection Bureau | Includes separation from electronic-delivery consent. General preprinted account language and preselected opt-in boxes do not satisfy it. | O; actual consent evidence held. |
| R010-P1-C035 | Account use or acceptance of an access device cannot, without an authorized separate basis, be substituted for affirmative overdraft consent. | S004, § 17(b)(1)(iii), comments 17(b)-5–6; S003, § 2(a). Consumer Financial Protection Bureau +1 | Different statutory/regulatory forms of acceptance must not be conflated. | I from R/O; no implied-consent finding. |
| R010-P1-C036 | An institution may require an account-opening yes/no choice, but silence is not opt-in. | S004, comment 17(b)-5. Consumer Financial Protection Bureau | No selected box/signature means no opt-in; offered accounts must comply with (b)(2)–(3). | O; not permission to require the “yes” answer. |
| R010-P1-C037 | Confirmation must record the consent and include the right to revoke; a completed notice copy or acknowledgment letter can suffice. | S004, § 17(b)(1)(iv), comment 17(b)-7. Consumer Financial Protection Bureau | Writing, or electronic if agreed; oral confirmation does not satisfy the disclosure requirement. | R/O; actual content and delivery unknown. |
| R010-P1-C038 | The confirmation timing standard concerns transactions paid after confirmation is mailed or delivered. | S004, comment 17(b)-7; S010, 31667–31668. Consumer Financial Protection Bureau +1 | Comment recognizes compliance through reasonable procedures designed to ensure that timing. Consumer receipt is not required before a fee; later fee posting alone does not cure the payment-timing issue. | O/H; actual procedures and any error remain unresolved. |
| R010-P1-C039 | Covered overdraft fees may concern only overdrafts paid on or after receipt of affirmative consent, subject also to confirmation requirements. | S004, comment 17(c)-1. Consumer Financial Protection Bureau | Later consent does not retrospectively validate fees for earlier paid transactions. | O; event times unknown. |
| R010-P1-C040 | The opt-in notice must be substantially similar to A-9, include every applicable required item, and contain only specified or permitted information. | S004, § 17(d). Consumer Financial Protection Bureau | Specific § 17 rules govern permissible content and format. | R; no current form visual-comparison conclusion. |
| R010-P1-C041 | The notice must explain the service and relevant transaction types; other-transaction policies must not overshadow the opt-in right. | S004, § 17(d)(1), comment 17(d)-1. Consumer Financial Protection Bureau | Include discretion/possible decline explanation as applicable. | R/O; actual policy and accuracy unknown. |
| R010-P1-C042 | All applicable overdraft fees must be disclosed, including daily, sustained, and negative-balance fees; a variable fee requires its maximum. | S004, § 17(d)(2), comment 17(d)-2. Consumer Financial Protection Bureau | Amount can vary by number of overdrafts, overdraft size, or other factors. | R/O; no actual fee amount supplied or calculated. |
| R010-P1-C043 | The notice must disclose the maximum number of fees per day, or disclose that there is no limit. | S004, § 17(d)(3). Consumer Financial Protection Bureau | This is a disclosure requirement; it is not a national numerical fee cap or blanket permission under other law. | R/I. |
| R010-P1-C044 | The notice must explain the right to opt in and the means available for doing so. | S004, § 17(d)(4), comment 17(d)-3. Consumer Financial Protection Bureau | Methods must match what the institution actually offers. | R/O. |
| R010-P1-C045 | Offered linked-credit and same-institution account-transfer alternatives must be disclosed as applicable. | S004, § 17(d)(5), comment 17(d)-5. Consumer Financial Protection Bureau | Both offered means disclose both; one means disclose that one; neither means omit that reference. Other alternatives may be listed. | R/O; offering an alternative is not established here. |
| R010-P1-C046 | Section 17(d)(6) permits specified additional content concerning other-transaction choices, associated returned-item/merchant fees, revocation, and historical existing-account wording. | S004, § 17(d)(6). Consumer Financial Protection Bureau | Only as applicable; optional initial revocation wording does not eliminate mandatory revocation information in confirmation. | R. |
| R010-P1-C047 | A-9 can be tailored to offered consent methods; a tear-off form and a decline box are not invariably required. | S004, comments 17(d)-3–4. Consumer Financial Protection Bureau | Reasonable account-identification methods are permitted; no identifiers are entered in this pass. | O; no specific form approved. |
| R010-P1-C048 | Appendix A comments do not give blanket approval of institutional forms or every fee charged under them. | S005, Appendix A comments 1–3; S004, § 17(d). Consumer Financial Protection Bureau +1 | Accurate use of appropriate model language concerns proper disclosure form; specific § 17 content limits remain. | O/I; no individualized safe-harbor or liability decision. |
| R010-P1-C049 | Historical A-9 text was fully read; current A-9 pixels were not. | S005–S006; S011, 81021. federalreserve.gov +1 | The 2011 text-continuity statement supports historical comparison, not an assertion of current visual inspection. | H/U; current visual/read completeness remains partial. |
| R010-P1-C050 | Section 4’s general permission to combine disclosures does not override § 17’s specific segregation and content restrictions. | S003, § 4(b); S004, § 17(b)(1)(i), (d); S010, 31671. Consumer Financial Protection Bureau +2 | Other material may be in the same mailing while the opt-in notice remains segregated. | R/H/I. |
| R010-P1-C051 | Regulation E permits another disclosure language if English is available on request. | S003, § 4(a)(2), comment 4(a)-2. Consumer Financial Protection Bureau | Applies alongside the required content and clarity standards. | R/O; actual language/accessibility facts unknown. |
| R010-P1-C052 | For joint accounts, one set of required disclosures may be provided to any account holder. | S003, § 4(c)(2). Consumer Financial Protection Bureau | Separate § 17(e) governs whose consent or revocation binds the account. | R; disclosure delivery is not itself consent. |
| R010-P1-C053 | Institutions offering EFT services jointly may allocate compliance by agreement, but § 4(d)’s knowledge limitation expressly concerns §§ 7 and 8. | S003, § 4(d). Consumer Financial Protection Bureau | Does not itself create a § 17 exception for the account-holding institution. | R/I; actual actor allocation unknown. |
Claim ID · Precise claim / area · Source and pinpoint · 22 data rows
| Claim ID | Precise claim / area | Source and pinpoint | Trigger, conditions, exceptions | Status / limits |
|---|---|---|---|---|
| R010-P1-C054 | An institution cannot condition paying check/ACH/other overdrafts on ATM/debit opt-in or decline them because opt-in was refused. | S004, § 17(b)(2), comment 17(b)(2)-1. ecfr.gov +1 | Apply the same payment criteria consistently; this does not compel payment of every check or ACH item. | R/O. |
| R010-P1-C055 | Consumers declining opt-in must receive the same other account terms, conditions, and features. | S004, § 17(b)(3), comment 17(b)(3)-1. Consumer Financial Protection Bureau | Includes interest paid, fees, card capabilities, minimum balance, and online bill pay; exception is the protected overdraft service itself. | R/O. |
| R010-P1-C056 | Independently justified limited-feature accounts remain possible, but refusal to opt in cannot be used to divert an otherwise eligible consumer to them. | S004, comment 17(b)(3)-2. Consumer Financial Protection Bureau | Actual eligibility and account terms required. | O; no creditworthiness decision. |
| R010-P1-C057 | Without opt-in, the institution may pay the covered transaction but cannot charge for paying it. | S004, comment 17(b)-2. Consumer Financial Protection Bureau | Debit of principal is preserved only if permitted under other applicable law. | O; no debt-validity, collection, or setoff conclusion. |
| R010-P1-C058 | Opt-in does not guarantee authorization or payment of an overdraft. | S004, comment 17(b)-3. Consumer Financial Protection Bureau | Contractual or other obligations are not adjudicated here. | O. |
| R010-P1-C059 | Section 17(b) covers the relevant debit card only when issued by or on behalf of the account-holding institution. | S004, comment 17(b)-1.i. Consumer Financial Protection Bureau | Third-party issuance without the “on behalf of” relationship is outside that stated scope. | O; actual issuance/funding relationship unknown. |
| R010-P1-C060 | A one-time debit-card transaction can qualify whether conducted at POS, online, or by telephone. | S004, comment 17(b)-1.iii. Consumer Financial Protection Bureau | Channel location does not substitute for recurring/one-time classification. | O. |
| R010-P1-C061 | The coding reliance rule requires systems adapted to identify one-time versus recurring transactions. | S004, comment 17(b)-1.ii. Consumer Financial Protection Bureau | After that condition is met, merchant/institution/third-party coding may be relied upon. | O; coding accuracy, system adaptation, and actual reliance not established. |
| R010-P1-C062 | The fee prohibition applies to all otherwise covered institutions, including those with a general decline policy. | S004, comment 17(b)-1.iv. Consumer Financial Protection Bureau | An institution charging no fees for these paid overdrafts need not perform the § 17(b)(1)(i)–(iv) notice/opt-in process for that fee-free service. | O; no general policy-based fee exception. |
| R010-P1-C063 | Positive authorization followed by negative settlement does not excuse a covered fee where the required opt-in was absent. | S004, comment 17(b)-1.iv. Consumer Financial Protection Bureau | Commentary’s express example includes intervening transactions reducing funds before settlement. | O; other timing configurations and actual balances held. |
| R010-P1-C064 | With no opt-in, a fee based on negative-balance amount is prohibited when that balance is solely attributable to protected ATM/one-time debit transactions. | S004, comment 17(b)-8. Consumer Financial Protection Bureau | Requires fee classification and sole attribution. | O. |
| R010-P1-C065 | Section 17 does not prohibit that amount-based fee when the negative balance is wholly or partly attributable to a check, ACH, or another nonprotected transaction. | S004, comment 17(b)-8. Consumer Financial Protection Bureau | Does not validate a separate per-item fee for an unconsented protected card transaction. | O; other law/contract held. |
| R010-P1-C066 | With no opt-in, daily/sustained/negative-balance/similar fees are prohibited when the negative balance is solely attributable to protected transactions. | S004, comment 17(b)-9.i. Consumer Financial Protection Bureau | Fee substance and causation govern; a new fee label does not answer causation. | O/I. |
| R010-P1-C067 | Section 17 does not prohibit those ongoing fees where a negative balance is wholly or partly attributable to nonprotected transactions. | S004, comment 17(b)-9.i. Consumer Financial Protection Bureau | Subject to the timing rule in C068 and actual remaining balance attribution. | O; no all-law fee authorization. |
| R010-P1-C068 | For a mixed negative balance, the ongoing-fee timing anchor is when the nonprotected transaction was paid into overdraft. | S004, comment 17(b)-9.i, -9.ii.C. Consumer Financial Protection Bureau | An earlier protected card overdraft does not supply that start date. | O; contractual period, units, calendar, and events unknown. |
| R010-P1-C069 | The official mixed-balance examples depend on expressly stipulated posting and deposit-allocation assumptions. | S004, comment 17(b)-9.ii, examples A–C. Consumer Financial Protection Bureau | Later deposits can alter which debit component remains; associated fees matter in the examples. Their sample amounts and periods are not national legal thresholds. | O/I; no mandatory universal allocation method or actual calculation inferred. |
| R010-P1-C070 | A conservative alternative permits avoiding ongoing fees unless the outstanding negative balance is solely attributable to nonprotected transactions. | S004, comment 17(b)-9.iii. Consumer Financial Protection Bureau | This alternative avoids calculating allocation of partial deposits; it is an alternative, not the only required method. | O. |
| R010-P1-C071 | Any joint consumer’s affirmative consent binds the account; any joint consumer’s revocation likewise revokes account consent. | S004, § 17(e). Consumer Financial Protection Bureau | Joint relationship must actually exist. | R; no requirement that every joint holder separately opt in or revoke. |
| R010-P1-C072 | A consumer may opt in at any time and revoke at any time through the means made available for consent. | S004, § 17(f). Consumer Financial Protection Bureau | Opt-in follows the notice’s manner; revocation access must reflect available consent methods. | R. |
| R010-P1-C073 | Revocation must be implemented as soon as reasonably practicable. | S004, § 17(f). Consumer Financial Protection Bureau | The section supplies no fixed number of days for this implementation. | R; actual elapsed time and practicability unknown. |
| R010-P1-C074 | Revocation alone does not require reversal of fees assessed before implementation of the revocation request. | S004, comment 17(f)-1. Consumer Financial Protection Bureau | Does not establish that earlier fees were lawful or excuse unreasonable implementation delay. | O/I; separate grounds remain held. |
| R010-P1-C075 | Consent continues until revoked by the consumer or the institution terminates the service. | S004, § 17(g), comment 17(g)-1. Consumer Financial Protection Bureau | Termination is possible; excessive use is the comment’s example. | R/O; no actual termination or reconsent finding. |
Claim ID · Precise claim / area · Source and pinpoint · 15 data rows
| Claim ID | Precise claim / area | Source and pinpoint | Trigger, conditions, exceptions | Status / limits |
|---|---|---|---|---|
| R010-P1-C076 | The original final rule distinguished its effective date from its mandatory compliance date. | S009, 74 FR 59033, index 0. govinfo.gov | Effective January 19, 2010; mandatory compliance July 1, 2010, with the specific existing-account transition. | H; historical regulatory dates, not individual deadlines. |
| R010-P1-C077 | The 2010 clarification removed former (b)(4); its correction preserved the four subparagraph requirements by specifying amendment of the introductory text. | S010, 75 FR 31671–31672; correction 33681. govinfo.gov +1 | Both effective July 6, 2010. | H; former (b)(4) is not a current fee exception. |
| R010-P1-C078 | The 2011 rule recodified Regulation E into Part 1005 without new substantive obligations. | S011, 76 FR 81020–81021. govinfo.gov | Effective December 30, 2011; transfer of relevant rulemaking authority described as July 21, 2011. | H; current duties come from current text. |
| R010-P1-C079 | Accounts opened before July 1, 2010 were not permanently grandfathered out of opt-in. | S004, § 17(c)(1). Consumer Financial Protection Bureau | Covered fees assessed on or after August 15, 2010 require § 17(b)(1) compliance and affirmative consent. | R; opening date/fee facts unknown. |
| R010-P1-C080 | Accounts opened on or after July 1, 2010 require compliance and consent before covered fees are assessed. | S004, § 17(c)(2), comment 17(c)-1. Consumer Financial Protection Bureau | Also apply consent/payment and confirmation timing. | R/O; no actual event-date calculation. |
| R010-P1-C081 | Opt-in is not a waiver of all EFTA protections or every other fee limitation. | S002, § 1693l; S004, § 17. uscode.house.gov +1 | Statute preserves greater protection and expressly excepts a waiver given in settlement of a dispute or action. | S/I; no settlement, enforceability, or remedy decision. |
| R010-P1-C082 | The 2024 overdraft final rule originally stated an October 1, 2025 effective date. | S012, 89 FR 106768 and § V. govinfo.gov +1 | It was a final rule with a future effective date when issued. | H/D; that planned date is not treated as having activated the disapproved rule. |
| R010-P1-C083 | Public Law 119-10 disapproved the specifically identified 2024 final rule and gave it no force or effect. | S013, 139 Stat. 53, entire operative sentence. govinfo.gov | Approved May 9, 2025; identifies 89 FR 106768, December 30, 2024. | S; exact enacted effect read. |
| R010-P1-C084 | The disapproved rule’s added comment 17(a)-2 and new covered-overdraft framework cannot be used here as current requirements or exclusions. | S012, 106837, index 69; S013; current S004. govinfo.gov +2 | The preexisting Regulation Z-line exclusion still exists on its own terms. | D/R/I; no new fee cap inferred from the disapproved rule. |
| R010-P1-C085 | The CFPB resource page’s May 12 signing date conflicts with the enacted public law’s May 9 approval date. | S014 featured paragraph; S013 heading and approval line. Consumer Financial Protection Bureau +1 | This report uses May 9, 2025 for enactment/approval. | Verified source discrepancy; resource date not substituted for statute. |
| R010-P1-C086 | Circulars 2022-06 and 2024-05 are withdrawn guidance under the inspected official status materials. | S015 register and 90 FR 20084–20086; S016 publisher pages. Consumer Financial Protection Bureau +4 | Withdrawal applicable May 12, 2025. | W; historical analyses not current-rule substitutes. |
| R010-P1-C087 | Withdrawal of those circulars does not itself repeal the statute/regulation or affirmatively validate all fees discussed in them. | S015’s specified withdrawal action; S002–S004. federalregister.gov +2 | Distinguish guidance status from the continued text and scope of statutes/regulations. | I from S/R/W; other legal grounds remain open. |
| R010-P1-C088 | A stipulated compliant opt-in does not settle the full legality of an authorization-positive/settlement-negative fee. | S004, § 17 and comment 17(b)-1.iv; C081, C086–C087. Consumer Financial Protection Bureau +2 | Other applicable statutory, contract, disclosure, balance-method, and judicial questions need their own authority and facts. | U; no current broader liability theory asserted. |
| R010-P1-C089 | The generic rules cannot determine actual consent, causation, coding, contract compliance, liability, eligibility, or relief without facts not supplied and not searched. | Analytical limit of C002–C088; user scope. | All actual identity, account, balance, timing, agreement, and transaction facts remain blank. | U; no individual or class-action determination. |
| R010-P1-C090 | The checked current-resource labels and retrieved bodies support this bounded report, but do not certify all intervening legislation, publications, litigation, or current form pixels. | S001–S018 and failure log. ecfr.gov +2 | eCFR title currency through October 23; selected OLRC labels through October 20; older statutory recoveries; unread current image. | U / methodological qualification; no component or parent closure. |
Example · Stipulated hypothetical facts · Section-specific result and remaining unknown · 15 data rows
| Example | Stipulated hypothetical facts | Section-specific result and remaining unknown | Evidence category needed | Adverse misclassification to avoid |
|---|---|---|---|---|
| E01 — No opt-in; paid one-time debit | All coverage predicates are stipulated; an account-holding FI pays a one-time debit-card overdraft; no affirmative consent exists. | § 17 prohibits a fee for paying it. Principal debit authority is separately conditional on applicable law. C018, C029, C057, C066. | Paid-item status, card relationship, channel, absence of consent, fee linkage. | Treating payment itself as consent; treating the fee prohibition as automatic principal forgiveness. |
| E02 — Affirmative opt-in; other conditions unknown | A separate affirmative choice is stipulated, but notice, opportunity, confirmation, and timing are unknown. | Fee authority under § 17 is not established merely by that choice. C029–C039. No actual violation or remedy is adjudicated. | Notice content/delivery, opportunity, confirmation, payment chronology, procedures. | Collapsing four cumulative requirements into “a consent box exists.” |
| E03 — Recurring classification uncertain | Debit-card payments recur in ordinary language, but advance authorization, further consumer action, coding, and adapted systems are unknown. | Classification remains unresolved. C016, C061. | Payment arrangement, initiation method, recurrence indicator, system adaptation/reliance. | Calling every repeated merchant payment recurring, or disregarding the commentary’s conditional coding rule. |
| E04 — Paid check or ACH | A transaction is stipulated to be a check or ACH debit, not an ATM/one-time card transaction; it is paid into overdraft. | The specific ATM/one-time-card opt-in prerequisite does not by itself prohibit the fee. C008–C009, C054, C065, C067. Other law and contract remain unknown. | Actual rail and paid status; fee type; governing contract. | Treating all EFTs as debit-card transactions; treating absence of this prohibition as universal legality. |
| E05 — No consent; other negative-balance source | No opt-in; the negative balance is stipulated to arise solely from a paid check or ACH transaction. | Comments 17(b)-8 and -9 do not prohibit the described balance-based/ongoing fee merely because there was no ATM/debit opt-in. C064–C068. | Complete causation and contract trigger. | Assuming every negative balance without opt-in is fee-free. |
| E06 — Revoked consent | A valid revocation has been implemented; a later covered one-time debit is paid. | The prior consent no longer supplies the opt-in predicate for a fee on that payment. C029, C072–C075. Earlier fees are not automatically reversed solely by revocation. | Revocation receipt, available methods, implementation, payment/fee events. | Treating revocation as retroactive cancellation of every prior fee, or as ineffective indefinitely. |
| E07 — Linked credit excluded | Payment is stipulated to occur pursuant to an overdraft line subject to Regulation Z. | Excluded from “overdraft service” under § 17(a)(1). C019. Credit agreement, APR, usury, origination, repayment, and other protections remain held. | Nature of credit line and funding mechanism. | Applying the § 17 opt-in rule as the complete law of the credit line. |
| E08 — Mixed transactions | No opt-in; protected card and check/ACH debits contribute to a continuing negative balance. | The protected card payment cannot carry its own unconsented overdraft fee. A separate ongoing fee requires the mixed-balance analysis and the nonprotected payment-date anchor. C064–C070. | Debit sequence, deposits/credits, allocation, associated fees, residual balance, fee period. | Letting one check validate all card fees; using the earliest card overdraft as the sustained-fee start. |
| E09 — Positive authorization; negative settlement; no opt-in | Covered one-time debit authorized when funds are believed sufficient; intervening activity leaves insufficient funds at settlement; no required opt-in. | The current comment expressly prohibits the fee for paying that transaction. C062–C063. | Authorization/settlement facts and consent status. | Treating a general decline policy or positive authorization as an exception. |
| E10 — Positive authorization; negative settlement; opt-in stipulated | All § 17 opt-in steps are stipulated satisfied; authorization and settlement balances differ. | This pass does not conclude that the fee is lawful or unlawful under all applicable law. C081, C086–C088. | Actual balance methodology, contract/disclosures, causation, independently applicable authority. | Using withdrawn Circular 2022-06 as current operative law, or treating its withdrawal as a universal permission. |
| E11 — Returned unpaid / NSF | The underlying item is stipulated to have been returned unpaid. | Classify the charge as a returned-item/NSF issue; the paid-overdraft fee rule alone does not decide it. A separate fee-collection EFT can implicate § 3(b)(3). C026–C027. | Returned/paid disposition; who assessed/collected the fee; collection method. | Calling an unpaid item a paid overdraft; confusing a merchant fee EFT with the FI’s own fee entry. |
| E12 — General agreement or account use only | The only stipulated acts are signing general account terms and using the account; no separate affirmative choice is stipulated. | Those acts do not establish the required separate opt-in. C034–C036. | Dedicated consent act and associated disclosure sequence. | Importing “use constitutes authorization” from a different rule. |
| E13 — Joint-holder revocation | A joint consumer revokes existing opt-in, with implementation stipulated. | Revocation operates for the account under § 17(e). C052, C071–C075. | Joint relationship and revocation chronology. | Requiring every joint holder to revoke, or treating one disclosure copy as every holder’s affirmative consent. |
| E14 — Prepaid negative balance | A product is called prepaid and has a negative asset balance; credit access, issuer relationships, decline policy, and fee conditions are unknown. | Neither § 17(a)(4) exclusion is established from the label or negative balance alone. C017, C022–C024. | Defined prepaid status; feature structure; issuer/affiliate/business-partner relationship; authorization policy; fee predicates. | Applying the prepaid exception to ordinary checking accounts or ignoring its no-prohibited-fee conditions. |
| E15 — ATM access fee | A non-account-holding ATM operator discloses its access fee and the consumer continues. | Analyze that operator fee under § 16; this does not itself establish § 17 overdraft consent to the account-holding FI. C028–C034. | Fee actor, fee purpose, screen/paper notice, separate overdraft process. | Treating acceptance of an ATM surcharge as overdraft opt-in. |
Field · Generic question / document attribute · Entry · 27 data rows
| Field | Generic question / document attribute | Entry | Claim / example links |
|---|---|---|---|
| W01 Product purpose | Is the asset account established primarily for personal/family/household or business purposes? | — | C002–C003 |
| W02 Account category | Checking/share draft/savings/prepaid/trust/other; which exact definition and exclusion governs? | — | C003, C017–C024 |
| W03 Actor role | Account holder, card issuer on its behalf, separate card issuer, ATM operator, merchant/payee, creditor, transfer-service actor? | — | C004–C006, C028, C053, C059 |
| W04 Geographic predicate | Account location and relevant statutory/regulatory residence/location predicates? | — | C015 |
| W05 EFT agreement | What generic agreement establishes EFT services, and which party’s agreement is relevant? | — | C006 |
| W06 Transaction rail/channel | ATM, one-time card, recurring card, ACH, check, converted check, wire, internal transfer, other? | — | C007–C016, C060–C061 |
| W07 Recurring classification | Advance authorization, substantially regular intervals, and further consumer action? | — | C016; E03 |
| W08 Coding reliance | Classification indicator, system adaptation, and basis for reliance on third-party coding? | — | C061; E03 |
| W09 Card relationship | Was the debit device issued by or on behalf of the account-holding institution? | — | C059 |
| W10 Payment disposition | Was the underlying item actually paid, declined, reversed, or returned unpaid? | — | C018, C026–C027; E11 |
| W11 Authorization/settlement | Relevant authorization and payment/settlement events; what does the operative rule actually answer? | — | C038–C039, C063, C088 |
| W12 Balance methodology | Ledger/available balance definitions, holds, unsettled items, posting order, reversals, and intervening credits? | — | C018, C063–C070, C088 |
| W13 Notice version/content | Service, transaction types, all fees, variable maxima, fee count, consent methods, offered alternatives, permitted additions? | — | C040–C047 |
| W14 Notice separation | Is the notice segregated from other information and the consent choice separate from other acknowledgments? | — | C030, C034, C050 |
| W15 Delivery/retention | Written or agreed electronic delivery; clear, understandable, retainable form; relevant language availability? | — | C030–C032, C051 |
| W16 Opportunity | What reasonable method and opportunity for affirmative choice were provided? | — | C033, C036 |
| W17 Consent act | What dedicated affirmative act occurred, and when was it received? | — | C034–C039 |
| W18 Confirmation | Written/agreed electronic confirmation, revocation statement, mailing/delivery event, reasonable procedures? | — | C037–C038 |
| W19 Joint relationship | Which joint-holder rule applies to disclosure, opt-in, or revocation? | — | C052, C071 |
| W20 Revocation | Method, receipt, implementation, practicability, and any later valid opt-in? | — | C072–C075 |
| W21 Fee classification | Per-item payment fee, balance-tier fee, daily/sustained fee, NSF, returned-deposit fee, transfer fee, credit charge, ATM surcharge, other? | — | C025–C028, C042–C043, C064–C070 |
| W22 Fee causation | Which paid transaction or remaining negative-balance components caused the particular fee? | — | C064–C069 |
| W23 Mixed-balance allocation | How do posting order, later deposits, associated fees, credits, and reversals affect residual attribution? | — | C068–C070; E08 |
| W24 Fee period and trigger | Disclosed contractual period; calendar or business-day units; starting event; continuing-balance condition; applicable exclusions? | — | C042, C068–C069 |
| W25 Linked arrangement | Reg Z line, own-account transfer, securities credit, qualifying prepaid feature, or another mechanism? | — | C019–C025 |
| W26 Other account terms | Same pricing/features and payment criteria regardless of opt-in; independent basis for any limited-feature product? | — | C054–C056 |
| W27 Unresolved governing facts | State/country/tribal status, contract terms, other legal limits, benefit protections, security/setoff, and other parent dimensions? | — | C081, C088–C090; parent holds |
Assigned subquestion / branch · Coverage · Claim / example links · 49 data rows
| Assigned subquestion / branch | Coverage | Claim / example links | Exact missing authority or facts | Next bounded permissible investigation |
|---|---|---|---|---|
| 1.a Enabling EFTA authority | Partial: substantive text read; currentness gap | C001; S001, S003, S011 | Current OLRC §§ 1693a–b bodies and complete later session-law lag audit. | Recover current official statutory text and check only relevant published amendments. |
| 1.b Consumer versus business account | Answered generically | C002–C003 | Actual primary purpose and account arrangement. | No actual-record inquiry authorized; maintain fact hold. |
| 1.c Bank/credit-union/other FI coverage | Answered generically | C004–C005, C053, C059 | Actual account-holder/issuer roles and any statutory excluded-person predicates. | Published definition clarification only; no institution/license search. |
| 1.d EFT-service agreement gateway | Answered generically | C006–C009 | Actual agreement, notice of third-party arrangement, transfer initiation. | Maintain fact hold. |
| 1.e Necessary EFT exclusions | Answered within relevant clauses | C008, C010–C014 | Actual rail, purpose, within-institution relationship, qualifying assets/plan. | Narrow public authority follow-up only if a specific legal ambiguity becomes material. |
| 1.f Geographic scope | Answered at federal gateway; broader scope held | C015 | Actual account location/residence; non-U.S. law. | No country-wide or international closure; separate bounded law review only. |
| 1.g Covered paid overdraft definition | Answered generically | C018 | Paid status, insufficient/unavailable funds, fee cause, account-holding actor. | Maintain fact hold. |
| 1.h Linked credit/own-account transfer/securities exclusions | Answered generically | C019–C021; E07 | Actual mechanism and agreement. | No credit-product or provider search. |
| 1.i Prepaid exclusion | Answered as conditional gate; product taxonomy partial | C017, C022–C024; E14 | Product facts; remote incorporated benefits/gift/tax definitions; historical prepaid-date chain. | Follow only a material published cross-reference; no full prepaid/credit closure. |
| 1.j Actual coding/classification | Unresolved facts | C016, C059–C061; E03 | Actual coding, adapted systems, reliance, recurring authorization. | No actual transaction search authorized. |
| 2.a Complete § 17 notice/consent/confirmation/revocation text | Answered; full section/comments read | C029–C047, C071–C080; S004 | Actual compliance facts only. | No additional generic authority needed for the stated text. |
| 2.b Segregated notice and separate choice | Answered generically | C030, C034–C036, C050; E12 | Actual presentation, dedicated choice, preselection. | Maintain fact hold. |
| 2.c Reasonable opportunity and methods | Answered generically | C033, C036, C044 | Actual opportunity and available methods. | Maintain fact hold. |
| 2.d Electronic delivery and retainability | Answered with authority-type distinction | C030–C032, C037 | Actual delivery agreement/retention; independent requirements for other documents. | Any further E-Sign work must identify the distinct legally required disclosure. |
| 2.e Confirmation timing | Answered generically | C037–C039; E02 | Mailing/delivery, consent receipt, transaction payment, reasonable procedures. | Maintain fact hold; no invented receipt deadline. |
| 2.f Complete required notice content | Answered generically | C040–C047 | Actual fees, service policies, alternatives, tailored text. | Compare only a permissible generic blank form if later needed. |
| 2.g Current A-9 body/image | Partial source retrieval | C049; S005–S006, S011 | Current image pixels and complete current image transcription not obtained. | Obtain readable official current form through permitted public tools; no access workaround. |
| 2.h Historical A-9 and current instructions | Answered within read bounds | C040–C049 | Historical-to-current visual comparison remains unverified. | Preserve distinction between historical parsed text and current image. |
| 2.i Revocation, joint holders, duration | Answered generically | C071–C075; E06, E13 | Actual joint status and event chronology. | Maintain fact hold. |
| 2.j Effective dates and existing accounts | Answered for § 17 transition/recodification | C076–C080 | Actual opening and payment dates. | No individual calendar calculation. |
| 3.a Complete fee prerequisite | Answered generically | C029, C057–C063 | Actual satisfaction of coverage and four conditions. | Maintain fact hold. |
| 3.b No conditioning of other overdrafts | Answered generically | C054 | Actual payment criteria and reason for decline. | No institutional practice investigation. |
| 3.c Same terms/features | Answered generically | C055–C056 | Actual comparative terms and independent eligibility. | No creditworthiness or account-eligibility decision. |
| 3.d Payment discretion versus fee authority | Answered generically | C057–C058; E01 | Applicable principal-debit law and contract remain unknown. | Preserve setoff/collection/contract holds. |
| 3.e Checks/ACH/recurring versus one-time card | Answered generically; classification facts unresolved | C008–C016, C059–C061; E03–E04 | Actual channel and recurring predicates. | Maintain fact hold. |
| 3.f Balance-amount fees | Answered generically | C064–C065; E05, E08 | Actual balance components and fee basis. | No ledger reconstruction authorized. |
| 3.g Daily/sustained/negative-balance fees | Answered generically | C066–C070 | Actual continuing attribution, contractual period, deposits and allocations. | Maintain fact hold; no universal period inferred. |
| 3.h Mixed-balance timing | Answered generically | C068–C070; E08 | Nonprotected payment date, period units, residual source. | Only generic further interpretation; no individual deadline. |
| 3.i Opt-in and other limits | Answered as limitation | C081, C088 | Broader governing law/contract and any settlement context. | Preserve parent holds. |
| 4.a Authorization-positive/settlement-negative without opt-in | Answered by current comment | C062–C063; E09 | Actual predicates, if any. | No withdrawn guidance needed. |
| 4.b Authorization-positive/settlement-negative with compliant opt-in | Unresolved broader legal basis | C088; E10 | Independently applicable law, balance/disclosure/contract facts. | If later necessary, inspect only material published primary authority; no docket query. |
| 4.c Withdrawn-guidance checks | Answered for every circular used for status | C086–C087; S015–S016 | No broader guidance-universe audit asserted. | Recheck official register only if another guidance item becomes necessary. |
| 4.d 2024/2025 final-rule disapproval | Answered for authority actually implicated | C082–C085; S012–S014 | Full unrelated provisions of disapproved rule not examined. | No need to revive its framework; retain exact statutory effect. |
| 4.e Paid versus returned/unpaid, NSF | Answered as distinction; broader law excluded | C026–C027; E11 | Actual disposition, actor and collection method; substantive NSF law. | Separate generic NSF component if later assigned. |
| 4.f Deposit advance, linked credit, setoff | Partial by intentional scope | C019–C025; E07 | Credit/security/setoff contracts and broader legal authority. | Preserve separate lending/setoff dimensions. |
| 4.g Published opinions/later litigation status | Excluded from conclusions; no case holding needed here | C088–C090 | No majority-opinion holding or later-history audit performed. | Only material published opinions if later strictly necessary; no case-record/docket-status query. |
| 5.a Blank audit worksheet | Delivered | W01–W27 | All entries intentionally blank. | No records request or identifier entry. |
| 5.b No-opt-in paid one-time branch | Delivered | E01; C029, C057 | Actual facts not supplied. | None within this published-source pass. |
| 5.c Affirmative consent, other conditions unknown | Delivered | E02; C029–C039 | Notice/opportunity/confirmation/timing facts. | Maintain hold. |
| 5.d Recurring classification branch | Delivered | E03; C016, C061 | Classification/coding/system facts. | Maintain hold. |
| 5.e Check or ACH branch | Delivered | E04; C008–C009, C054 | Channel and contract facts. | Maintain hold. |
| 5.f No consent, other negative source | Delivered | E05; C064–C068 | Causation and fee trigger. | Maintain hold. |
| 5.g Revoked-consent branch | Delivered | E06; C072–C075 | Receipt/implementation/payment chronology. | Maintain hold. |
| 5.h Linked-credit exclusion branch | Delivered | E07; C019 | Actual Reg Z credit arrangement. | Preserve credit-law holds. |
| 5.i Mixed-transactions branch | Delivered | E08; C064–C070 | Complete component allocation and timing. | Maintain hold. |
| 5.j Authorization/settlement branch | Delivered in two distinct forms | E09–E10; C063, C088 | With-opt-in broader legal basis remains unresolved. | No universal APSN conclusion. |
| Standards: current statutory/body/edition completeness | Partial | C090; failure log | Current bodies for identified statutes; complete intervening-publication audit. | Public primary-source recovery only. |
| Standards: UI/model provenance | Unverified beyond session identity | Opening provenance statement | Frontend and selector evidence unavailable. | No claim of unseen UI verification. |
| Parent/operational/publication acceptance | Excluded | Parent holds below | No authority or factual basis for acceptance/closure requested. | Preserve all holds; no operational action. |
User assignment · Principal claims · Principal sources · 6 data rows
| User assignment | Principal claims | Principal sources | Delivered examples / audit |
|---|---|---|---|
| 1. EFTA/Reg E consumer, account, institution, transfer coverage and exclusions | C001–C028, C059–C061 | S001, S003–S004, S007, S017 | E03–E04, E07, E11, E14–E15; W01–W12, W25 |
| 2. Complete notice, separate content/form, consent, confirmation, revocation, model, dates | C029–C053, C071–C080 | S003–S006, S008–S011 | E02, E06, E12–E13; W13–W20 |
| 3. Fee prohibition, conditioning, same terms, discretion, mixed-balance causation | C029, C054–C075, C081 | S002–S004, S010 | E01, E04–E08; W21–W26 |
| 4. Authorization/settlement, guidance withdrawal, repeal, unpaid/NSF/credit/setoff distinctions | C019–C028, C062–C063, C082–C090 | S003–S004, S007, S012–S017 | E07–E11, E14–E15; W10–W12, W21–W25 |
| 5. Blank audit and qualitative branches | C089–C090 and branch-specific claims above | Source-linked claim register | W01–W27 and E01–E15 |
| Standards and parent holds | C049, C081–C090 | Source table and read/failure log | Coverage table, self-check, parent holds |
Log item · What was actually read · What was not represented as read · 10 data rows
| Log item | What was actually read | What was not represented as read |
|---|---|---|
| L01 — Current § 17 | Entire operative § 17(a)–(g), all embedded official interpretations, all three mixed-balance examples, and the alternative method. Annual § 17 PDF text also read in full. | No claim that the whole of Regulation E, all related regulations, or all annual-CFR pages were read. |
| L02 — Necessary gateway | Relevant § 2 definitions; complete § 3 coverage/exclusion text and relevant interpretations; complete § 4; complete § 16 for the ATM-operator distinction. | No full error-resolution, unauthorized-transfer-loss, benefits, remittance, gift-card, or state-law investigation. |
| L03 — Linked/prepaid exclusions | Necessary § 1026.3(d) and § 1026.61 definition/exception text, including negative-balance conditions and business-partner exception. | No comprehensive Regulation Z, APR, origination, security, repayment, or credit-account compliance review. |
| L04 — A-9 | Current heading/link and current § 17(d)/Appendix A instructions; complete parsed historical one-page A-9; 2011 statement of substantive continuity. | No current A-9 pixels seen. No claim of complete current-image transcription or visual comparison. |
| L05 — Final-rule dates and explanations | Necessary 2009 dates/electronic-delivery explanation; relevant 2010 clarification passages and complete correction; 2011 recodification/A-9 passage. | Not every page of each historical preamble. Historical provisions superseded by later clarification were not treated as current. |
| L06 — Disapproval | Complete Public Law 119-10; the 2024 rule’s stated effective date, necessary discussion, and complete added § 17(a)-2 comment; agency status paragraph. | Not the entire 78-page disapproved rule or a broader Congressional Review Act reissuance analysis. |
| L07 — Withdrawal | Official register, operative withdrawal discussion, relevant listed circulars, and publisher-page identification/scope passages. | No wholesale adoption of historical circular analyses or their cited cases; no assumption that a live URL means current guidance. |
| L08 — Statutes | Official 2024 §§ 1693a–b and § 5519 recovery bodies; current-labeled § 1693l and § 7001 bodies. | No claim that annual recovery text or a compilation header establishes complete current session-law status. |
| L09 — Images and screenshots | Parsed PDF text and image-link metadata only. | PDF text is not pixels. Placeholder image results and the failed A-9 screenshot were not counted as image inspection. |
| L10 — Discovery exclusions | Search results were used to locate permitted primary bodies. | Search snippets, headnotes, secondary reports, proposed-rule summaries, incidental case/entity results, and unopened prototype forms were not substantive foundations. No actual-case search was pursued. |
Failure ID / source · Complete requested URLs or identified failed representation · Result and bounded consequence · 10 data rows
| Failure ID / source | Complete requested URLs or identified failed representation | Result and bounded consequence |
|---|---|---|
| F01 / S001 — Current § 1693a | https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1693a&num=0&edition=prelim ; https://uscode.house.gov/view.xhtml?req=%28title%3A15+section%3A1693a+edition%3Aprelim%29 ; https://uscode.house.gov/us/usc/119-134/t15/s1693a/ ; https://uscode.house.gov/us/usc/119-124/t15/s1693a/ ; https://uscode.house.gov/us/usc/119-121/t15/s1693a/ ; https://www.govinfo.gov/content/pkg/USCODE-2025-title15/html/USCODE-2025-title15-chap41-subchapVI-sec1693a.htm | Returned combinations of 404, page-not-found, disabled/inaccessible results. Recovered official 2024 body, S001. Current statutory lag remains unresolved. |
| F02 / S001 — Current § 1693b | https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1693b&num=0&edition=prelim ; https://uscode.house.gov/us/usc/119-134/t15/s1693b/ ; https://uscode.house.gov/us/usc/119-124/t15/s1693b/ ; https://uscode.house.gov/us/usc/119-121/t15/s1693b/ ; https://uscode.house.gov/us/usc/t15/s1693b/ ; https://www.govinfo.gov/content/pkg/USCODE-2025-title15/html/USCODE-2025-title15-chap41-subchapVI-sec1693b.htm ; https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapVI-sec1693b.htm | 500/inaccessible responses. Recovered official 2024 PDF body, S001. No inference of missing authority. |
| F03 / S001 — Current chapter fallback | https://uscode.house.gov/view.xhtml?edition=prelim&req=granuleid%3AUSC-prelim-title15-chapter41-subchapter6 | 404. Did not close statutory-currentness gap. |
| F04 / S002 — § 1693l path and repeat retrieval | https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1693l&num=0&edition=prelim ; https://uscode.house.gov/us/usc/119-134/t15/s1693l/ | Old path failed; modern body initially succeeded. One direct repeat failed; reopening the retrieved reference again returned the complete body. Recovered, with header limit preserved. |
| F05 / S017 — Current § 5519 | https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title12-section5519&num=0&edition=prelim ; https://uscode.house.gov/us/usc/119-134/t12/s5519/ ; https://uscode.house.gov/us/usc/t12/s5519/ | 404/inaccessible. Recovered 2024 official body, S017. No actual excluded-person determination. |
| F06 / S004 — Fixed annual § 17 URL | https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-sec1005-17.pdf | Fixed path inaccessible. Recovered complete 2026 § 17 through the Govinfo link URL in S004. |
| F07 / S005, S011, S018 — Current A-9 representation | Current PNG and appendix URLs in S005; embedded graphic in S011; full-part annual PDFs in S018. | Current image returned a placeholder; appendix extraction supplied heading but not full form body; PDF extraction omitted the graphic text. Current pixels/full-image transcription remain unverified. Historical parsed model recovered through S006. |
| F08 / S018 — Large 2026 CFR PDF | Both 2026 full-part URLs in S018. | Initial header/text success followed by targeted find/open timeouts. No full-part body-read claim. |
| F09 / S004, S006, S013 — Screenshots | § 17 PDF indices 0–2; public law index 0; historical A-9 index 0. | Earlier calls supplied image placeholders without inspectable image content. The historical A-9 screenshot returned an inability-to-resolve/screenshot-not-enabled error despite parsed PDF availability. No pixel-read claim. |
| F10 — Search-domain restriction | Search service reported a non-retryable robots restriction for https://www.congress.gov/ during generic legislative discovery. | No workaround attempted. The enacted public-law body was read from Govinfo, S013; no Congress.gov body is claimed read. |
Check · Result · 12 data rows
| Check | Result |
|---|---|
| Independent primary-source investigation, without prior-report foundation | Performed. No unreviewed Library report or prior chat was used. |
| Complete focused § 1005.17 operative text and official interpretations | Read, including exclusions, all four conditions, notice content, conditioning, same terms, joint relationships, revocation, duration, and mixed-balance examples. |
| Statute versus regulation versus official interpretation versus guidance | Separated in source and claim statuses. |
| Current, historical, future-effective, disapproved, withdrawn, unknown | Separated. The 2024 rule’s planned effective date was not treated as operative; withdrawal was not treated as statutory repeal. |
| Current A-9 image read | Not achieved. Historical parsed text and current instructions are explicitly distinguished from current pixels. |
| Current statutory/edition/session-law audit | Partial. Identified current-body failures and older official recoveries are preserved. |
| Fee-causation reasoning | Qualified. Per-item, amount-based, ongoing, mixed-source, and returned-item branches are separated. |
| Authorization/settlement treatment | Bounded. No-opt-in example answered from the current comment; broader with-opt-in legality held. |
| Numerical integrity | No invented fees, awards, or deadlines. Regulatory thresholds stated are sourced; no individual arithmetic performed. |
| Actual-record, entity, identifier, or docket investigation | None conducted. |
| Individual liability, class eligibility, standing, remedies, filing advice | No determination made. |
| Component, state, parent, operations, or publication acceptance | None given. |
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Recorded check status: conditional framework reviewed source currentness form actualfact limits retained
Keep the source version, actual read extent and jurisdiction with the proposition. A link or researcher access claim is not a substitute for an operative primary passage.
Recorded check status: fresh selected historical body
Recorded check status: fresh selected historical body and current route failure
Recorded check status: fresh selected partial group
Recorded check status: fresh selected body
Recorded check status: fresh selected partial group
Recorded check status: fresh selected historical body
Recorded check status: fresh selected partial group
Recorded check status: fresh selected body
Recorded check status: fresh selected historical partial group
Recorded check status: fresh selected historical partial group
Recorded check status: fresh selected historical partial group
Recorded check status: fresh selected historical partial group
Recorded check status: fresh selected body
Recorded check status: fresh selected status body
Recorded check status: fresh selected status body
Recorded check status: unreopened historical publisher pages
Recorded check status: fresh selected historical body
Recorded check status: unreopened recovery attempt history
The saved component-level coverage record keeps answered, partial, blank and unresolved branches distinct. A coverage label is not acceptance of a whole subject or jurisdiction.
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
No currently queued material correction is mapped to this component. This does not remove its currentness, access, jurisdiction or application limits.
accepted with limits
Original saved Markdown SHA-256: 104f35aa30d1780d527b933e66920e2f1c6155f509fe453ef744fdb5b5e91d9e. Public formatting, private-reference removal and correction annotations are separate from that immutable original.
