We are allowing accounts to be OD as much as long as 45 days prior to closure. I'm OCC regulated & don't think this is a problem but want to confirm we are not in violation of something!

Thanks

I know of no regulation regarding when you have to charge off OD accounts. In most banks that I have worked it was at the 30 day threshold, but they may be more of an industry standard. One word of caution if you are allowing ODs on savings accounts, since you are not allowed to net OD amounts for certain reporting purposes, you may want to check your savings accounting systems, as most savings systems do not properly track ODs.

The FDIC has reviewed our program of classifying ODs over 30 days as "doubtful" and setting up a 50% reserve and then charging them off at 90 days if there is no activity to clear the account. There are no black and white regs for FDIC regulated banks.

Continuing ? For savings accounts is there a law that prohibits a bank from overdrawing the account. For example, checks that were deposited into a savings account are returned. Thanks

While not traditional, I believe we are seeing this more and more. The question isn't can a savings be overdrawn, but why can't it? I know of no technical or legal prohibition.

I also do not know of any legal prohibition, but have seen systems that would not tolerate it. It was something akin to an anatomically impossible act.

While there is no reg requiring charge offs, you should review state law. We are required to charge off after 30 days or reserve 100%.