Refunding Overdraft Fees

One of the invaluable features of our webinars is the ability to ask questions. You can pre-submit questions about the webinar topic or ask them live and we will issue written answers to those questions.

Here’s a question we received about refunding overdraft fees:

Question: We have started monitoring fee refunds, particularly overdraft fee refunds, and have run into instances where an overdraft fee was absolutely justified yet we have employees refunding such fees simply to make the customer happy. Is this a problem?

Answer: You do want to be careful with refunding fees that are justified. Overdrafts are incidental credit, so there can be fair lending risks. For instance, if you refund fees for some but not others on what appears to be a prohibited basis or that impact a protected class, it could be viewed as illegal discrimination. We recommend some type of roadmap and/or guidelines for employees to follow when refunding fees.

To learn more be sure to check out our webinar, “What You Need to Know About Overdrafts”, which is available now OnDemand.

Some of our attendees had this to say:

  • Having the current information as to what is going on in the industry helps me stay in compliance. I can make changes prior to the examiners coming in.
  • Great current information and as always, I love the plain English explanations.

Deposit Operations Training

Published 2026/11/09

Amy Kudlacek

Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!

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