Overdraft Programs have always been a hot button area for examiners, especially for the CFPB, who has had Overdraft Programs on its radar since its inception. In recent months other regulatory agencies have issued guidance to caution financial institutions on the assessment of various overdraft fees. Yet despite the guidance, white papers and other communications that have been issued by the agencies, there is still confusion over which elements actually apply to the programs you offer. The regulators want to ensure your Overdraft Program practices do not intentionally or unintentionally result in consumer harm, and you want to protect your institution from UDAAP and other regulatory violations.
What You’ll Learn
- Guidance for ad hoc versus automated OD programs
- Opt-in/Opt-out process required by Regulation E
- How to identify inherent risks of your OD program
- How to develop effective policies and procedures
- Overdraft restrictions for employees and insiders
- Ongoing monitoring of accountholder activity
- Understand the impact of UDAAP
- Marketing your OD program compliantly
- Best practices for disclosing OD fees
- Effectively reporting OD program details to the board and management
Who Should Attend
This session is designed for New Accounts Personnel, Branch Managers, Deposit Operations Staff, Compliance Officers, Risk Officers, and Internal Auditors.