We do not have a overdraft protection product. We charge an NSF fee and for those days in which the account remains negative, we charge 15% and it's disclosed at account opening. Can you charge for the negative balance on days that fall on weekend and bank holidays?

How do you separate the balance to only charge the 15% on the overdrafts caused by checks versus one time debt card transactions and ATM withdrawals? When a customer makes a deposit, which overdraft balance is extinguished first? Just my personal opinion, you agree to pay a check into the overdraft and then charge them an NSF fee and 15% interest on the balance rather than just returning the check for which they get one charge. Why? And 15%? I hope that these fees and interest rates are fully justifiable by the bank and are not considered unconscionable. As too whether you can charge over the weekend, that would be a matter of State law, unless you feel that would be considered a UDAAP. Hard to say, but the program appears to be a little draconian from the get go.

I would recommend you google class action lawsuits related to overdraft programs. No saying you are going to be sued but this is how some big banks have gotten in trouble.

I agree with both posters above, yikes.

Thank you for the guidance. I plan to change it, I'm of the same opinion.