Has anyone completed an audit of this area? We just started our program so I am doing a review at this time and I haven't been able to find a program. Currently I am reviewing the contracts, letters, repayment plans, compliance, policies/procedures, and testing accounts. Can anyone think of areas I am missing? I want to be sure to try to include as much as I can the first time around. Any input would be appreciated.

Recommendations would depend on how your OD program works. Whether or not there is interest associated with a repayment program would make a big difference, otherwise it sounds like you have a lot of the bases covered. Really check the disclosures if there is a free checking account tied to the program, that it meets the regulatory definition of "free" - See Commentary for Reg DD. Also, if there is a variance in the amount that you charge fees for someone with OD privileges vs. someone who is not...could lead to unfair practices.

Is the PC that the software program is loaded on secure? No internet access or unauthorized employee access? (Well that could wait until your Information systems audit.)

These are just some thoughts.

Our program doesn't charge any interest and the only fees are the NSF charges, and that is regardless of whether you are in the program or not.

One item I have run into, though, is that the 4 payments are either over or short a penny or two depending on the amount owed.

I reviewed IL914 and I think we are okay with all of the items mentioned for compliance. Are there any other publications/issuances I should review? I really don't care for the OTS search feature, I can never really find what I am looking for.

It sounds pretty good to me! I think that some banks either do not offer this product or they have not had it long enough to develop an audit program, this may be why you aren't finding much information about it.

From Department of Financial Institutions-State of Tennessee:

One area to pay close attention to will be the consistency in the disclosure of balances in monthly statements, ATM displays, transaction receipts, telephone and internet banking services and any other medium for providing account information. The balances provided should be well defined, and the definitions disclosed to customers in a clear, understandable format upon opening an account or upon any changes in balance definitions. This includes disclosing the fact that a balance reflects the net amount of funds remaining in an account following processed deposits and withdrawals as well as any overdraft limit incorporated in an overdraft program. Failure to provide this information in an understandable format with the apparent motive of increasing overdrafts and fees may be viewed as a misleading business practice.

If an overdraft program dictates that the payment of insufficient fund transactions is at the bank's discretion, the decision making process concerning whether or not to pay should be objective and consistent. However, if any overdraft program includes a written obligation on the bank's part to pay checks written on an account with insufficient funds, such payments might be considered open end credit, and consequently may be subject to applicable statues that dictate lawful interest rates, finance charges, and disclosure infromation.