We currently have a program where a consumer may link their savings account to their checking account and if the checking account were to go overdrawn, a transfer from the savings account would keep the checking in the positive, this service comes with a fee per transfer. Is there anything that would prohibit this type of program only instead of a savings linked to a checking situation, it would be a checking account linked with the checking account? What regulatory pitfalls would there be, or UDAAP for that matter?

If properly disclosed I not sure how this would be an issue. You are providing a service that helps customers avoid OD fees (not too many banks do that).

Agreed. No difference. Just be sure that ownership of both accounts is the same.

Thank you all!