Agreed. You should have a policy regarding overdraft programs to set the parameters within which procedures must work. Just as an example, because of the regulatory vibes out there, a bank might adopt a policy ban on imposing "continuing overdraft" fees or on the imposition of an overdraft fee when an overdraft is created by the posting of a fee. Then when some hotshot proposes that you change a program to add a daily overdraft fee (another name for a "continuing overdraft" fee), calmer heads can point to policy and say "Whoa! We don't play that game here!"
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8