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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
Overdrafts – A Current View
Questions and Answers