Calculating the De Minimis Amount for Overdrafts

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Question:

In regard to the changes in overdraft protection programs, can the de minimis amount where we do not charge a NSF fee be the total of the overdraft daily or is it a de minimis amount per check?

Answer:

The suggestion for a de minimus overdraft fee comes from recent FDIC guidance. That guidance is not directed at overdraft protection plans which generally involve lines of credit or transfers from other deposit accounts.

Any de minimus amount you establish would be on a "per day" basis, not a "per item" basis.

First published on BankersOnline.com 3/28/11