One thing certain about the Regulation E overdraft requirements passed last November is that they go into effect for new accounts July 1 and existing accounts Aug. 15. What is uncertain is the impact the new regulations will have on credit union income.

Callahan & Associates and the Filene Research Institute both attempted to shine some light on the possible impact the regulations will have on credit unions' bottom line.

Callahan Industry Analyst Lydia Cole estimated the potential changes in credit union noninterest income from Reg E. In 2009, Cole said that credit union noninterest income totaled $11.6 billion and that NSF and courtesy pay fees accounted for 28.1% of total noninterest income, which equals approximately $3.26 billion in income for the credit union industry. Since Reg E does not require consumer opt-in for check and recurring ACH payments, Cole estimated fee income from those sources will remain the same, but an estimated $1.82 billion from debit, point-of-sale and ATM overdraft fees is up in the air. The impact a credit union will see in fee income relates to how many members choose to opt-in, but Cole estimates the potential effect on credit union ROA will likely be around 10 basis points.