The 2005 interagency guidance on overdraft protection suggests monitoring excessive consumer usage. At the June 2010 ABA Compliance Conference some regulators also suggested banks identify and work with excessive use consumers as an exam prep step. Can anyone share how they define "excessive usage", their frequency of monitoring and process for following up with customers? Also, has anyone had examiners ask about this monitoring?

We identify customers who have 5 NSF's in one day or 10 in the last 30 days.

We call them and counsel them by asking if they need help balancing their checkbook, explain sweeps by either a savings account or line of credit, etc.

We follow up the phone call with a letter. At that point, they have 10 business days to return the letter indicating they still want to have overdraft protection. If the letter is not returned, they are removed from our overdraft protection program. If they choose to remain in the program, their account must be kept in good standing.

These procedures were given to branch management by our compliance officer.

If we are unable to contact the customer by phone after 3 attempts, we forward the details to him.