Overdraft Changes & What You Need to Know

Date: March 2, 2011

The Federal Deposit Insurance Corporation (FDIC) has issued final guidance on its supervisory expectations for overdraft payment programs, setting new expectations not addressed by previous guidance. FDIC banks have until July 1, 2011, to comply. This webinar will examine the potential regulatory and financial effects of the new guidance, including how it differs from previous expectations. Presenters also will address the potential effects on financial institutions regulated by different agencies. The webinar includes procedural consequences, potential costs, customer effects and revenue challenges of complying with this guidance.


Those of you that participated in our March 2, 2011, webinar on ‘Overdraft Changes & What You Need to Know,’ should have received a follow-up Q&A document explaining our thoughts on the questions we received from participants.  In addition, we attempted to clarify the meaning of the phrase “six overdraft occasions where a fee is charged,” from the Federal Deposit Insurance Corporation (FDIC)’s Supervisory Guidance.  We relayed our discussion with a member of the FDIC review staff in the Kansas City Regional Office, who indicated, based on recent internal training provided to examiners, the phrase “six overdraft occasions” referred to six occasions where an account balance goes from above zero to below zero and in which one or more overdraft fees is charged.  However, during a recent webinar regarding its overdraft guidance, the FDIC stated unequivocally that “an occasion occurs each time an overdraft transaction generates a fee.”  The FDIC confirmed this position through an FAQ posted on its website.  We suggest you closely review this document, as it provides further clarification to items discussed during our webinar and in our follow-up Q&A.

If you have additional questions, please contact your BKD advisor.


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