Are Overdraft Programs OK Again?

Learn how to structure and manage an overdraft program that addresses regulatory expectations, consumer protection concerns, UDAP/UDAAP risk, and today’s evolving compliance environment.

Overdrafts are certainly a topic we've heard a lot about lately. Are they outlawed? (Hint: No). Has the administration commented much on them? (Not really). Should we consider eliminating them? (Hint: No need, but with certain conditions). Even though there is no specific regulation on them per se, over the years we have seen some institutions eliminate overdraft fees (and NSF fees as well) entirely, while others are considering reinstituting them. Are these concerns that should be considered by every institution? Regardless, it is important to understand exactly what is at issue and how to manage your program.

In this session, we'll discuss the various types of overdraft programs out there, as well as the many statements and guidance from regulatory agencies over the past few years. We'll also talk about risk management, particularly around consumer protection and UDAP/UDAAP. We'll discuss some best practices to ensure your program is doing exactly what you expect it to be doing, and how to handle the many risks that come with this timely topic.

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