Overdrafts are certainly a topic we’ve heard a lot about lately. Are they outlawed? (Hint: No). Has the new administration commented much on them? (Not yet). Should we consider eliminating them? (Hint: No, but be careful). Even though there is no specific regulation on them per se, we have seen some institutions eliminating overdraft fees (and NSF fee as well) entirely, while others are considering reinstituting them. Are these concerns that should be considered by every institution? Regardless, it is important to understand exactly what is at issue and how to manage your program.
What You’ll Learn
- Should we eliminate overdraft (and/or NSF) fees?
- Coverage under Reg. Z?
- Discussions in Congress and at the regulatory agencies
- Overdraft reform from the OCC, CFPB, and others
- Overdrafts as UDAP/UDAAP? Considerations and factors
- Are overdraft and NSF fees “junk fees”?
- Authorized Positive, Settle Negative (APSN) issues
- Differences between overdraft and NSF
- Different types of overdraft programs and their risks
- Compliance risks of overdrafts according to various regulations
- Historical guidance and risk factors
- Metrics to consider
- Making the right decisions for your institution
Who Should Attend
Anyone curious about the current state of affairs when it comes to overdraft and related programs – whether it be fees, disclosures, or related issues.
