We are not an FDIC regulated bank so I understand that we are not under the guidance to have 'meaningful follow up", however, I'm curious what other non-FDIC banks are doing (or not doing) for customers who are habitually overdrawn and have opted-in. As year to date fees travel into the $1,000's, what responsibility do we have to our customer to contact them, discontinue their opt-in service, or lower their overdrafting limits?

I come from an FDIC regulated bank so my views are rather conservative and I would like insight on what is normal for our peers.

FDIC regulated or not, the following was in the joint guidance from the other regulatory agencies.

Monitor overdraft protection program usage. Monitor excessive consumer usage, which may indicate a need for alternative credit arrangements or other services, and inform consumers of these available options.

That joint guidance is 12 years old but to the extent it hasn't been superseded by regulatory change (the Reg E opt-in, for example), it's still valid.

In addition, a failure to inform habitual overdrafters of other options could potentially be seen as a UDAAP.