Client Alert: Overdraft Programs
Overdraft programs are receiving increased scrutiny from both regulators and plaintiffs’ attorneys, focusing on overall fairness, effective disclosures and management oversight. Private litigators have primarily focused on banks that combine certain transactions (e.g., check, POS, ATM and ACH) and process them from highest to lowest dollar amount for the sole purpose of maximizing customer overdraft fees, while federal banking agencies continue to implement expansive laws, regulations, and guidance surrounding the day-to-day aspects of overdraft programs. This is an area in which banks must be diligent.
The Financial Institutions Group has prepared a Client Action Alert discussing recent regulatory activity with suggested action items to help bank clients navigate this area of increased scrutiny. Please click below to read the Alert.