I was recently re-reviewing the Overdraft Guidance and FAQs and need some input to determine if my interpretation is correct. As I interpret the guidance if you have some sort of automated process for decisioning overdrafts, regardless of credit lines or additional overdraft bounce protections, even with a majority of your decisions being made ad-hoc that the institution would be required to follow the guidance to have a formalized overdraft program.

Example:
Step 1: Automated process that applies criteria to decide to pay overdraft, not to pay overdraft, or refer to officer.
Step 2: Automated process that applies additional criteria to decide to pay overdraft and waive fee, pay overdraft and charge fee, not pay overdraft and waive fee, not pay overdraft and charge fee.
Step 3: Ad-hoc process of overdraft reviewed by officers or branch managers

If institution has either process described in step 1, step 2, or both, then regardless of step 3 you have an automated system and required to follow overdraft guidance and have formalized overdraft program.

Any opinions would be welcome!