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Course description

Where are we on the subject of bank overdraft programs? The Bureau has studied the topic almost since it opened its doors in 2011. After a flurry of activity during the Cordray years, the Bureau has now moved its overdraft project to an “inactive list” pending appointment and confirmation of a permanent director of the agency. In the meantime, various overdraft practices are being criticized, not only by the Bureau, but also by prudential regulators. Everything points to making sure banks are transparent in their provision of overdraft services and avoid consumer harm in efforts to increase overdraft fee income. Whether or not the Bureau ultimately takes regulatory action to restrict overdraft service offerings or mandate better disclosures is anyone’s guess, but it’s critical that financial institutions avoid practices that continue to draw regulatory criticism or trigger consumer class-action lawsuits. Attend this two-hour webinar to get a current view of regulatory requirements and developments affecting overdraft programs, including --

  • What the CFPB is focused on in its review of OD practices
  • A review of the account disclosure requirements related to overdraft fees
  • A cautious look at Regulation DD account advertising requirements when overdrafts are mentioned
  • Statement disclosure requirements
  • The opt-in disclosure requirements under Regulation E
  • Regs E and O - Does "no opt-in, no fee" apply to insiders, too?
  • Key provisions of the FDIC's Guidance and the follow-up FAQ
  • The FDIC's OD fees/Reg E/UDAP stance and what it means to you
  • Best practices and practices to avoid
  • Published exam procedures
  • Recent court cases and regulatory enforcement actions involving overdraft payment programs


John Burnett

John Burnett is a 1979 alumnus of the ABA National Compliance School, and served on its faculty for several years. He graduated with honors with the Class of 1990 from ABA's Stonier Graduate School of Banking, and is also a graduate of the BAIs and the Massachusetts Banker Associations Schools of Banking.John began his banking career in high school when he started as a teller at a $15 million bank that didn't have account numbers for its checking accounts (he says they actually filed by signature!) He joined Cape Cod Bank and Trust Company in 1971 and assumed the position of Compliance Officer in 1976. He also served as corporate secretary and secretary of CCBT's Board of Directors, as well as Clerk of the bank's holding company. John joined Glia Group, Inc. and the team in June, 2004. He is a frequent presenter of BOL Learning Connect webinars, and at BOL Conferences events.He was a member of the Massachusetts Bankers Association Legal and Regulatory Compliance Committee, and a former member of the American Bankers Association Compliance Executive Committee and NCS/NGCS Advisory Board. He served on ABA's Truth in Savings Task Force as Regulation DD was being written, and has served on several ABA and Massachusetts Bankers seminar panels.

Course curriculum

  • 1


    • Overdrafts – A Current View

  • 2


    • Attendance Sheet

    • Materials

    • Slides

    • Questions and Answers