I'm saying that examiners will want to know why you decided to do (or not do) the things in the guidance. We do not have a formal overdraft program, but decided to implement some of the items in the newly released FDIC guidance. Sometimes we were limited by what our core system could do, and we made sure to document that and have everything in a file. That way, we won't be shrugging our shoulders saying "I dunno" when the regulators are here.
My own personal opinion: I'd recommend complying with as much of the guidance as you can, based on your systems, the cost of complying, and the type of overdraft activity/program you have at your institution.
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We're all here 'cause we've lost control.
Innerpartysystem