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Email In an opinion written by U.S. District of Delaware circuit judge Stephanos Bibas that begins, “A good template serves as a guide, not gospel,” Del-One Federal Credit Union was denied the safe harbor typically proffered by use of model forms in a potential class action regarding its overdraft fees. https://www.cadwalader.com/resources/articles/regulation-e-model-forms-may-not-always-be-a-safe-harbor