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Overdraft Protection, Call Reports, and "Unfunded Committments"

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Question: 
We recently implemented John Floyd's Overdraft Privilege Program and we understand that some examiners are requiring banks to carry each account that has ODP on the Call Report as a "Unfunded Committment". We thought that since these limits were non-contractual that they would not be considered "Unfunded Commitments".
Answer: 

I would clarify with the examiner what the cite is.

If there is no contract and no commitment exists, than there is nothing to report as unfunded. The bank can opt, at its discretion, to return all NSF items so there is nothing unfunded.

I am not familiar with the program you are discussing but if you are not following Reg. Z disclosures there is certainly no line of credit and no unfunded commitment.

First published on BankersOnline.com 11/4/02

First published on 11/04/2002

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