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#2146276 - 09/15/17 03:30 PM Monitoring Excessive Overdrafts
Scappers7123 Offline
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Joined: May 2017
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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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rlcarey
Joined: Jul 2001
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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.
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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
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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That joint guidance is 12 years old but to the extent it hasn't been superseded by regulatory change (the Reg E opt-in, for example), it's still valid.
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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
USA
In addition, a failure to inform habitual overdrafters of other options could potentially be seen as a UDAAP.
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