This session will provide an overview of the relevant regulations on automated overdraft protection programs (ODP). We will focus on the issues that banks and credit unions have encountered during recent compliance examinations.
If your institution’s ODP has not yet been examined for compliance, you may be in for an unpleasant surprise. Your institution is expected to read, understand, and apply guidance documentation-- you must follow the ebb and flow of informal Examiner expectations.
Examiners are raising many issues about ODP, including: the sufficiency of disclosures related to alternatives available to your customers; the overdraft program itself (i.e., account transfer services, revolving lines of credit, etc.); whether your FI's monitoring program is robust enough; and, conducting areview of any claims of unfair, deceptive and abusive acts or practices (UDAAP).
Clearly, compliance today is much more than following the law verbatim. It is difficult to keep up with every publication, study, guidance document, and enforcement action to which the Regulators have access.
During this session, we will delve deep into various "front burner" topics, in a consolidated and concise manner, to help you fully understand what is expected of your institution.
The session will answer the following questions:
Why is an overdraft service is welcomed by consumers (rather than being seen as a "gotcha" product)?
- Are all overdraft programs subject to regulatory scrutiny?
- What is the impact of a CFPB decision?
What types of overdraft programs are examiners most likely to focus on?
Does my program match regulator expectations? Do you have dynamic overdraft limits; debt denial tracking; dynamic communication; detailed reporting; and dedication to compliance?
What new overdraft guidance and information has been issued?
What is coming in the future for overdraft programs?
And much, much more . . .
Who Should Attend
This program is designed for Chief Operations Officers, Operations Administration, Compliance Officers & Compliance Staff, Risk Managers, Retail Operations Managers, Internal Audit Managers, Compliance Auditors, Internal Audit staff, and In-house Counsel.