Overdraft Programs & Disclosures: 12 Ways to Avoid Exam Issues
Overdraft programs have always been a hot button for examiners, especially for the CFPB, who has had overdraft programs on its radar since its inception. Over the last few years, the regulatory agencies have had a renewed focus on overdraft fees. Exam findings indicate there is still confusion over which elements of the issued guidance and regulatory statements actually apply to the programs offered by community financial institutions.
AFTER THIS WEBINAR YOU’LL BE ABLE TO:
- Understand regulatory guidance for ad hoc versus automated overdraft programs
- Explain the opt-in/opt-out process required by Regulation E
- Identify the inherent risks of your overdraft program
- Distinguish the difference between static and dynamic overdraft programs
- Develop effective policy and procedures to support your program and address the latest overdraft guidance
- Effectively report overdraft program details to the board and management
WEBINAR DETAILS
Regulators want to ensure your overdraft program practices do not intentionally or unintentionally result in consumer harm, and you want to protect your institution from UDAAP and other regulatory violations. This session will delve into the regulatory guidance in detail. It will review how to mitigate risks associated with offering overdraft protection. You’ll learn the pitfalls of representment fees, APSN transactions, and managing “opt-ins” for ATM and debit card transactions to offer overdraft protections. In addition, best practices for disclosures, fees, accountholder education, and marketing of your overdraft program will be covered. This session will also review overdraft program issues identified through consumer complaints, examinations, and enforcement actions, and provide recommendations for avoiding similar mistakes.
WHO SHOULD ATTEND?
This informative session is designed for new accounts personnel, branch managers, deposit operations staff, compliance officers, internal auditors, and anyone responsible for your overdraft program.
