Overdraft Programs: How to Prepare for Regulatory Scrutiny

In this session we will review the regulatory guidance in detail. In addition, we will discuss best practices for disclosures, fees, accountholder education, and marketing of your overdraft program. We will also review Overdraft Program issues identified through consumer complaints, examinations, and enforcement actions and provide recommendations for you to avoid similar mistakes.

Recorded Friday,
July 21st, 2023
Presented by Dawn Kincaid
2h total length
$279.00 or 1 Token

Includes: 30 Days OnDemand Playback, Presenter Materials and Handouts

  • Auditing
  • Compliance
  • Deposit
  • Deposit Accounts
  • Deposit Compliance
  • Risk Management/Legal
  • Branch Manager
  • Compliance Officer
  • Deposit Operations Manager/Specialist
  • Internal Auditor
  • New Accounts Representative
  • Risk Manager
  • Senior Management
  • Trainer

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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.

Dawn Kincaid

Instructor Bio

Dawn Kincaid began her banking career while attending The Ohio State University. She has 19 years of experience in client service, operations, information technology, administrative and board relations, marketing, and compliance. Most recently Dawn served as the Senior Vice President of Operations for a central-Ohio-based community bank, where she created and refined policies and procedures, conducted self-audits and risk assessments, and organized the implementation of new products and services. Dawn has served in the roles of Compliance, BSA/AML, CRA, Privacy, and Security Officer. She has led training initiatives, prepared due diligence information, completed a variety of regulatory applications, coordinated internal and external audits, and exams, and presented for numerous state associations.