A compliance firm that we use for input on some of our policies recently told us that we could not have the verbiage "account holder has 30 days to bring their account to a positive balance" on our Overdraft Privilege policy. A recent training that I attended stated that we should Establish a Time for Repayment. I read over the June 8, 2011, OCC guidance that they are basing this off and Reg DD and I cannot find where it says that we cannot have a timeframe.

Does anyone know where they are getting this from?

I would be asking them for a citation, since it is their claim. Why pay a consulting firm to go chase your own tail?

The OCC June 8, 2011, "guidance" was a proposal. It has never been finalized.