Overdraft Programs: Avoiding an Exam Disaster
This session provides a comprehensive review of OD regulatory guidance, including a discussion of how to address representment fees and overdraft fees resulting from APSN transactions in your policies and procedures. We will discuss how to develop effective policy and procedures, and best practices for handling the representment process and related fees. We’ll discuss best practices for disclosures, fees, accountholder education, compliant marketing of OD programs, and ongoing monitoring of accountholder activity. We will also review OD issues identified through consumer complaints, examinations, and enforcement actions and provide recommendations for you to avoid similar mistakes.