Monitor programs for excessive or chronic customer use, and if a customer overdraws his or her account on more than six occasions where a fee is charged in a rolling twelve month period, undertake meaningful and effective follow-up action, including, for example:
*Contacting the customer (e.g., in person or via telephone) to discuss less costly alternatives to the automated overdraft payment program such as a linked savings account, a more reasonably priced line of credit consistent with safe and sound
banking practices, or a safe and affordable small-dollar loan;4 and
*Giving the customer a reasonable opportunity to decide whether to continue fee-based overdraft coverage or choose another available alternative.
Here's the question...If you call that customer according to this and that customer continues to be overdrawn and incurring fees for the next week, do you keep calling them each day? It is still a rolling 12 months. It sounds stupid and I figure we decide how we are going to handle it for ourselves but what is reasonable? What are other banks going to do?
I've got a problem for your solution...