I'm trying to gather research on how other banks are going about implementing the FDIC guidance regarding overdrafts. I already got some information from contacts I have at other banks, but I thought I would ask here as well.
Mostly, it's pertaining to these items:
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; and
 Giving the customer a reasonable opportunity to decide whether to continue fee-based overdraft coverage or choose another available alternative.
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My questions:
- How are you defining "occassions"? Number of fees, number of transactions, number of days?
- In-person and via telephone are examples of ways to contact the customer. Would mailing a letter/notice also be acceptable? The other banks I've talked to indicated that they're planning on doing letters only and other contact would be left up to the branch employees.
- I know some other banks have already limited the number of fees they will charge in a given day. Can any of you provide examples of how you are limiting, or have already limited, OD fees? We are looking at doing something (limit-wise) but would like to get an idea of where others are on this.
****EDITED TO ADD: I am not asking how much you're charging or thinking about charging. I'm mostly asking if you're going to consider having a limit on daily fees or going to a more "fee corresponds to amount of OD" type of thing.***
Thank you!
Last edited by Aggs; 01/20/11 09:00 PM. Reason: Clarify
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