We have a letter which goes out when a customer has six overdrafts in a twelve month period. Our vendor says we only need to send one notice a year. Is this enough?

Everyday they have an overdraft, we send them a notice about encouraging good recordkeeping, auto transfers, loan products, mobile alert, online alerts, Reg E options and financial education options.

When this all started, our FDIC examiner told us we need to send a notice every time they hit 6. So they hit 6, we send a notice and reset the counter. Hit 6 again, send another notice and rest the counter.

ksm --

Personal opinion:
I suspect you may be doing a little overkill. After enough of those notices, all that helpful information becomes like so much wallpaper. No one will read it.

In researching posts related to the requirement to notify our customer when they have had six overdrafts in the last 12 month period, I ran across this. We do what Dani York does above, which I agree with John, is overkill. What can we get by with that will not be scrutinized by regulators and is not overkill. We are reviewing our entire program and this is one area that I need some help with.

IMHO, if you're an FDIC-supervised bank, Dani York's approach seems about right. That said, don't forget that the venerable 2005 ODP Guidance suggests notifying your customer each time that the ODP is used. And all of today's regulators signed on to that guidance document.

But even if you do send a notice each time the program is used, including a lot of info on alternatives with each and every notice is simply more wasted paper headed for the landfills. I'd deliver that sort of information on a more limited basis.