Opting a customer out of card-related overdraft coverage
12/03/2017
Should we opt a customer out of ATM/debit card overdraft coverage if we have either suspended the courtesy overdraft limit on their account?
Jerod Moyer
Bio:
Jerod is the leader of Banker's Compliance Consulting's seminar and training productions. His background includes over 16 years in the regulatory compliance field. He is an accomplished teacher and conducts various compliance seminars and webinars for Banker's Compliance Consulting. Jerod has also been a speaker for the American Bankers Association and BankersOnline; many state banking associations and schools, as well as, various webinars.
Jerod is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru.
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Questions Answered
Dynamic vs. uniform overdraft limits
11/26/2017
What is your opinion of having a set limit for courtesy OD coverage limits for all accounts versus having a dynamic OD coverage limits per account based on activity through an automated program.
Delayed courtesy pay access for new accounts
11/19/2017
We have a 30-day waiting requirement before a new customer gets a courtesy pay limit, but we do try to capture the opt-in response at account opening. Is that considered delaying the benefit? We would not charge any OD fees if there is no overdraft coverage, and there would not be coverage if there is no courtesy pay limit.
Dealing with excessive overdraft activity
11/12/2017
If a customer doesn't opt in and continues to have debit transactions that overdraw an account what is the bank’s course of action with this customer?
Changing overdraft coverage
11/05/2017
If the amount of the overdraft coverage changes according to the pattern of deposits and the customer is not informed about the change, can that be consider a UDAAP issue?
Flood determination content
08/06/2017
When completing a flood determination, is the borrower's name required on the form? Our audit department is listing it as a finding on their exam since the borrower’s name changed after the flood determination form was generated.
When the flood map changes
07/30/2017
Is a bank required to notify borrowers when property is no longer located in a SFHA?
Choosing a service provider
07/30/2017
How do we prove the customer picked a provider and the bank did not?
Is the building insurable?
07/23/2017
How do you know if a low value building has an insurable value? Do you determine this by determining if it is insured on the borrower’s hazard policy?
Choosing the property value label
07/23/2017
If we have an internal evaluation, would that be appraised property value or estimated property value?