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#2146276 - 09/15/17 03:30 PM Monitoring Excessive Overdrafts
Scappers7123 Offline
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Joined: May 2017
Posts: 5
We are not an FDIC regulated bank so I understand that we are not under the guidance to have 'meaningful follow up", however, I'm curious what other non-FDIC banks are doing (or not doing) for customers who are habitually overdrawn and have opted-in. As year to date fees travel into the $1,000's, what responsibility do we have to our customer to contact them, discontinue their opt-in service, or lower their overdrafting limits?

I come from an FDIC regulated bank so my views are rather conservative and I would like insight on what is normal for our peers.

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#2146284 - 09/15/17 03:53 PM Re: Monitoring Excessive Overdrafts Scappers7123
rlcarey Offline
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Joined: Jul 2001
Posts: 79,279
Galveston, TX
FDIC regulated or not, the following was in the joint guidance from the other regulatory agencies.

Monitor overdraft protection program usage. Monitor excessive consumer usage, which may indicate a need for alternative credit arrangements or other services, and inform consumers of these available options.
The opinions expressed here should not be construed to be those of my employer:

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#2146356 - 09/15/17 07:59 PM Re: Monitoring Excessive Overdrafts Scappers7123
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,629
Cape Cod
That joint guidance is 12 years old but to the extent it hasn't been superseded by regulatory change (the Reg E opt-in, for example), it's still valid.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2146573 - 09/18/17 11:37 PM Re: Monitoring Excessive Overdrafts Scappers7123
InFairness, CRCM Offline
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InFairness, CRCM
Joined: Nov 2010
Posts: 648
In addition, a failure to inform habitual overdrafters of other options could potentially be seen as a UDAAP.
Opinions are strictly my own, and have nothing to do with my employer.

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