Would anyone on here who offers an overdraft service, such as overdraft privilege, and requires their customers to opt-in to the service, be willing to share your opt-in form? Do you include the opt-in to the model A-9 form for payments of overdrafts on ATM and one-time POS transactions? Or do you have a separate opt-in form for the actual overdraft service?

We currently do not ask our customers to opt-in to the service. It is an automatic service, but they are given the option to opt-out at account opening. It has been suggested, by a reviewer, that we have them opt-in at account opening instead and I'm just trying to figure out the best way to do that. With a separate form or with the model A-9 form.

Thanks!

My first question would be who is the "reviewer?" I'd probably push back unless they had good reason to make this suggestion, and the switch wouldn't be too much of a problem. I previously worked for a bank that made this change, and it was not an easy adjustment. They did use the A9 form, and added a line at the bottom to opt in to overdraft, and then the regular A9 opt in. They created a separate document to explain the overdraft program, but kept the opt ins together on the A9.

Every other FI I've been with has had automatic opt in to regular (ACH/Check) overdraft programs without issue.

Monster - it is an outside reviewer that we have paid for years to come in annually and do multiple reviews. The same reviewer has made this suggestion to us twice this year, once during our compliance review and once during our UDAAP review. It was not a ding, simply a suggestion. However, I feel like it is a strong suggestion since he has brought it up twice now.

I do have a model A-9 form that allows the customer to opt-in to overdraft privilege as well as opt-in to ATM and one-time POS transactions. This was provided to us by our vendor. I'm just not real keen on it and would like to keep it separate.

I was just looking for examples of how other FIs handle this if they are requiring an opt-in to their overdraft program.

Thanks!

I understand. It was just a lot more of a 'to do' than expected. Aside from the opt in document changing, the system capabilities on each affected product, automated notices, frontline training, account opening, marketing, customer understanding, etc. all had to be changed.

It is easy to recommend improvements, and walk away. It is another thing to work through them issue by issue. It just isn't a battle I'd side with again, especially if overdraft income didn't show us to be an outlier from peers.

Good luck in whatever you end up doing! I agree the overall overdraft opt in on the A9 isn't ideal, I believe we went that route to avoid additional documents requiring signature/uploading/scanning and so on.

Most "review" programs have a clear understanding that the bank isn't required to make recommended changes. While there could be some regulatory brownie points for including an opt-in for any OD service, this change may not be one your bank wants to make.