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Financial institutions offer various types of overdraft services, some of which are subject to Regulation Z and some of which are not.  Whether Regulation Z applies depends on whether fees imposed in connection with those services (overdraft fees) are considered finance charges.  When the Federal Reserve Board first adopted Regulation Z in 1969, it created special rules for determining whether overdraft fees are considered finance charges.  While the nature of overdraft services, including how accounts can be overdrawn and how financial institutions determine whether to advance funds to pay the overdrawn amount, has significantly changed since 1969, the special rules remain largely unchanged.  The CFPB is considering developing proposed amendments to Regulation Z with respect to these special rules.