Let me preface my post by stating, Safety and Soundness is NOT my strong suit. (And, FWIW, I even sometimes wonder if Compliance is!)
As such, I would like to resurrect this thread with the following questions:
1. I've seen the interagency guidance on overdrafts, but where can I find a regulatory citation for this "requirement."
2. Does any law/regulation include a definition for "uncollectable?" [For instance, if the customer's account balance lives in the realm of the negative, but they continually have regular, ongoing deposits (direct or manual) never (or only occasionally, possibly even outside of the 60-day time-frame) reaching a positive balance, would the account be considered uncollectable?]
3. Does an intraday positive balance reset the 60-day count? [For example, a customer is overdrawn $500, but makes a $600 deposit, bringing the account to a positive status at some point during “daylight” hours, but at the end of the day other items clear (e.g., checks totaling $200) taking the customer back into the negative. So, although the customer’s ledger balance was technically positive (if only for a few moments), the system never registered the account as being in the black. Would this scenario allow for a "restart" of the clock?]
"Remember no man is a failure who has friends." - Clarence (the Angel) Oddbody - It's a Wonderful Life