This has been the experience of several financial institutions recently. While the usual “available balance vs. ledger balance” conversation seems to have crept back up, there have also been a few newer developments, such as the treatment of re-presented items and legal agreements.
1. Do you really know what balance your system is utilizing to determine when an overdraft fee is to be charged?
2. How do you treat re-presented items? If you charge a fee related to them, do you adequately disclose this?
3. Are your disclosures and legal agreements (i.e., Terms and Conditions) clear when it comes to overdraft-related items? In other words, do you do what you say, and say what you do?
It has been our experience that nearly 100% of the time, one of the areas mentioned above is being handled or disclosed incorrectly. THIS IS A BIG DEAL! If you don’t know the answer to these questions, or if you think you know the answer and want to want to know if it’s the right answer, please call us at 800-847-1653!
Do you want more on the “why” behind these questions? Be sure to check out the March 2020 edition of our Magazine, Banking on BCC. Do you want more on these issues and overdraft compliance in general? We have an Overdrafts Webinar coming up on July 30, 2020. Stay tuned to our website store as registration information will be available soon!
Get a sample of our magazine. Simply email us at consultants@bankerscompliance.com and see what it is all about.
Published
2020/04/07