Overdraft Protection Program

I am going to audit our Overdraft Protection Program separately and was wondering if anyone had procedures for this that they would be willing to share.

Thanks!

I have one but it does not include the recent Reg E changes or the new FDIC guidance which goes into effect this summer. PM me if you are interested.

Unless you are referring to a review of a program where you protect consumers against overdrafts via linked accounts or a line of credit, I suggest you change the name. A more accurate title might be "Overdraft Services Audit."

Thanks AJ and Ken.

I would recommend you include as a step in your audit to pull a list of customers and the fees they paid in the program during the last year. Then sort the list by the fees paid, if you are in shock when you look at the bottom, dont forget to consider UDAP. I used the best practices guidance and the commercial bank exam manual to help build a program. You should be able to take the 2005 and 2010 guidance and have a pretty solid start, just answer each bullet, and then consider the introductory statements in the guidance for your overall assessment.