How are others handling the restitution for OD/NSF Fees for charged-off accounts? Are you offsetting balance due to the bank or are you sending a check? Any guidance from your examiners?

offsetting balance first, and if dunds left over sending a check. regulator approved

I'll add a plug for the FCRA. Make sure any negative reporting is updated to reflect the correct amount owed if the offset isn't enough to satisfy the amount owed, or remove the negative report altogether if the offset satisfies the amount owed because the examiners would say that the account never should have been charged off if the fees weren't charged in an unfair way.

Seconding this!