Paul.... Very well laid out.  Thank you.

Bottom line... negative consumer deposit (savings accounts in Fineract) routinely go negative, with and without, formal arrangements and with (but also without) account holder opt-in.

If what I am now guessing is correct, that Fineract does not readily support a force-post, what is the best path forward.

Again, we are happy to do all the lifting and contribute the work product to the community, of course, expecting independent review and oversight.

Campbell


On 1/10/2026 10:37 AM, Paul wrote:
*Regulation E (Electronic Fund Transfers):* For one-time debit card and ATM transactions, banks cannot charge an overdraft fee unless the consumer has explicitly *opted in*. However, even without an opt-in, a bank is legally permitted to pay the transaction (creating a negative balance) as long as it does *not* charge a fee.
--

Herring BANCORP®

*C. Campbell Burgess
*President/CEO
Office: (806) 373-3921 | Direct: (806) 242-3704

[email protected]


*Herring Bancorp*
2201 Civic Circle, Suite 1000
Amarillo, TX 79109

www.herringbank.com <http://www.herringbank.com>

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