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.