The foundation for the OCC piece isn’t “new,” but it’s a more compact and sophisticated analysis than they’ve offered before and the examination procedures are exhaustive.
In your shoes, I would call the vendor and say: "Given the new team, we are having second thoughts about implementing the software. Please provide another demo." They’ll do it. The last anecdote they want out there is that a bank bought their software then decided not to use it. Regardless of all other facts, there’s simply no way you should flip a switch on this if your group doesn’t really understand how it works – banks cannot turn over their decision making processes to vendors.
If the vendor sold your predecessors on the idea that the software would increase fee income that would be completely unrealistic unless the software could automatically raise the “maximum” overdraft amount for many consumers. Any vendor selling that idea in the current environment should be banished to the thinking chair. It’s purely predatory.
On the other hand, the software could be a great compliance tool. If your bank can retain control over the maximum overdraft amount (regardless of the analytics), the software could be a huge improvement in justifying your bank’s claim that it actually underwrites its overdraft decisions at the account level. If the limit for consumer customers is $400, but the software can decide that $250 is all Rufus gets today then your bank clearly read the portion of the guidance dealing with credit risk. (Even if you disclose a potential $400 limit to Rufus, you are not obligated to pay to that limit; if you were, this would be a line of credit subject to Reg Z, state usury laws, etc.) If the software can also track and report on “frequent fliers,” so much the better.
Know that you will need to do some documented testing to assure that the software works the way you were told that it works.
Honestly, I would encourage you to hear what the vendor has to say, but until they fully understand the software, your team's only responsible vote is “No.”
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.