Vendor Guru Q&A - Compliance

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Latest Compliance - Overdraft Protection Topics

Overdraft Transfers and ACH Transactions

09/16/2018

I have been setting up overdraft transfers for funds trying to pull from savings for ACH transactions. They have funds in their checking, and when I set it up and then repost occurs, the funds are transferred from checking along with a transfer fee. Do you know if I am breaking any rules? Normally I would be transferring funds manually. Or should we just be returning the items.

Regulation on Reporting Charged Off ODP

06/03/2018

If we report our ODP accounts to the credit bureau and one gets charged off, what is the regulation for how many months can it be reported?

ODP: Have there been changes?

12/11/2016

Has the CFPB issued any regulations concerning overdraft payment programs?

Overdrafts and UDAP

11/27/2016

Is UDAP (Unfair or Deceptive Acts or Practices) a concern with overdraft services?

Disclosing account balances

11/20/2016

May a financial institution disclose a single balance inclusive of overdraft protection funds (i.e. a line of credit or discretionary service amount)?

Maximizing overdraft income

11/13/2016

May a financial institution process transactions in a manner that allows the financial institution to maximize overdraft fee income?

Reg E overdraft opt-ins

04/24/2016

We do not approve overdrafts unless a customer has a line of credit or ties a savings account to the checking. Should we be obtaining an opt-in so we can charge a fee if the customer does not have available funds in the line of credit or savings account?

Discontinue an AOD Program after Several Years?

06/09/2014

Can a bank discontinue an AOD program after it's been in place for several years?

Advance On OD Line of Protection- Notice?

05/12/2014

When an advance is made on an overdraft line of protection is a notice (advance notice) required to be sent to the Borrower? If so, which regulation does this fall under?

Request OD Protection Again After Reg D Violation

04/01/2013

A customer's savings account is set up to protect his checking via overdraft protection and he has violated Reg D for three consecutive months and the bank has removed the overdraft capability, following all requirements of course. When can he or can he request overdraft protection from his savings to his checking again?

Premium Content View All

UDAAP and Overdraft Protection

FDIC has issued warnings about the possibility of certain overdraft protection programs failing the UDAAP test. It has happened.

Gift Horses and Pigs in Pokes

There is a lot of wisdom-based guidance in maxims that have been used for centuries. "Don't look a gift horse in the mouth" is a popular one.

Info on Deceased Customer's Safe Deposit Box

10/20/2019

We received a call from a customer's child asking for information about a safe deposit box in name of our customer who is now deceased. This person was listed on signature card but never signed it. Should we give him any information regarding the closing of the box?

Latest Compliance - Overdraft Protection Topics

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