Skip to content
BOL Conferences
Thread Options Tools
#1812973 - 05/10/13 01:08 PM FDIC Exam and Ad Hoc Overdrafts
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,267
The West
I recently joined an FDIC bank that has an ad hoc program for overdrafts. My past experience is with a FRB regulated institution with a courtesy overdraft program.

We are in the San Francisco region. What can I expect during this exam?
_________________________
TryingToComply
CRCM

Return to Top
General Discussion
#1813019 - 05/10/13 01:52 PM Re: FDIC Exam and Ad Hoc Overdrafts TryingtoComply
manimal Offline
Diamond Poster
manimal
Joined: Feb 2008
Posts: 2,207
Deleted
I would take a look at the FDIC guidance that came out a few years ago (FIL 81-2010). Here's a link:

http://www.fdic.gov/news/news/financial/2010/fil10081.html
_________________________
We're all here 'cause we've lost control.

Innerpartysystem

Return to Top
#1813020 - 05/10/13 01:53 PM Re: FDIC Exam and Ad Hoc Overdrafts TryingtoComply
Norman Paperman Offline
Diamond Poster
Norman Paperman
Joined: Aug 2012
Posts: 1,709
48.934476, -114.343735
Do you have an internal policy for employees/officers are to handle the overdrafts? If you don't, you should. If you do, stick to it and make sure it is fair.

We have an ad hoc program (FDIC Bank) and our exam went fine. Are your debit cards live?
_________________________
Maybe you just wanna fly the plane yourself. Well good luck pressing take off, then auto pilot, then land.


CRCM

Return to Top
#1813052 - 05/10/13 02:24 PM Re: FDIC Exam and Ad Hoc Overdrafts TryingtoComply
Reads Regs Offline
Diamond Poster
Joined: Nov 2004
Posts: 2,310
The FDIC updated their ODP exam procedures in 12/2012. Have you reviewed them? http://www.fdic.gov/regulations/compliance/manual/pdf/V-13.1.pdf
_________________________
Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.

Return to Top
#1813470 - 05/12/13 12:00 PM Re: FDIC Exam and Ad Hoc Overdrafts Reads Regs
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Thanks. The examination procedures are definitely worth reading, but it's like watching a farmer plow the field from north to south and then do it again from east to west. "Just in case you didn't see it the first time you read it..."
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#1813483 - 05/12/13 11:26 PM Re: FDIC Exam and Ad Hoc Overdrafts TryingtoComply
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
I have been plodding through them and that is a good description.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top