Overdraft Compliance Risk Management Program

Recorded: November 6, 2024
Presented by: Ginger McCullough, Manager, Forvis Mazars, LLP.

Fees, including overdrafts have been heavy focus for the regulatory agencies in the past few years.  Financial institution staff of all levels must understand what is required to maintain a compliant overdraft program and which practices may be challenged by regulators and attorneys.

We continue to see new and re-interpreted guidance from the CFPB, FDIC, and the OCC as recent as September 2024 with the CFPB’s Circular on Documenting Affirmative Consent.  This heightened scrutiny signals institutions – large and small alike – to continue to improve their overdraft programs.

Overdraft compliance is so much more than being in compliance with clear-cut rules (e.g., Regulation E, DD, and O).  Rather, we must ensure doctrines of fairness, supervisory guidance, UDAAP, and safety and soundness implications.

Join us for this two hour webinar as we review the key elements of overdraft service requirements, guidance and regulatory expectations, ensuring your overdraft compliance risk management program is up to par, best practices, examiner findings and more. We will also highlight the key trends triggering potential violations and litigation.

During the Overdraft Compliance Management Program webinar we will cover:

• Overdraft Compliance Management Program
• Regulatory Requirements
• Key Regulatory Guidance and Expectations
• Risk assessment considerations
• Emerging risks
• Best Practices
• Examiner Findings