Overdrafts

I have some questions about overdrafts: https://www.fdic.gov/news/events/overdraft/faq.html#q2

1. Would a standard approach be reviewing customers with, let's say, more than 3 overdrafts in a month to see if there is a pattern of behavior?

2. That these overdrafts would be three or more calendar days in a calendar month where one account would have an overdrawn balance?

3. Should we look across multiple accounts owned by a client (e.g. three separate accounts for the same client were overdrawn for one day in a month)?

4. Does the dollar value matter? E.g. would three $1 overdrafts be considered as abuse?

5. If the FDIC wants a bank to contact their client when there is abuse, what message would the Account Officer normally convey?

Thanks.

Where are you getting three? And it is only an overdraft on which you charge a fee, so if you do not charge for overdrafts under $25, they do not count.

The Guidance states that FDIC-supervised institutions should monitor programs for excessive or chronic customer use, and if a customer overdraws his or her account on more than six occasions where a fee is charged in a rolling twelve-month period, undertake meaningful and effective follow-up action.

Sounds like there is one "trouble" customer.

Do you seriously assess an OD charge if a customer is overdrafted by $1.00? Tell me which bank to stay away from!

Has this been updated since Covid? I imagine banks have been a little bit more lenient?

There really have been no updates in the last 11 years.

The only real updates have been the number of banks offering "no overdraft" accounts, not any changes in regulatory positions.