Answer:
Answer from John:There's no specific requirement that you have either policy, although it makes sense to have at least some well-designed procedures for handling overdrafts. If anything, you should ensure that your overdraft policy and procedures cover your implementation (if any) of the new rules.
Answer:
Answer from Andy:If you have these issues addressed in existing policies, they should be checked for accuracy under the new rules and your new practices. As a personal preference, if you do have two policies and they have cross-over as to content, I like to address issues in one policy, and have the second refer to that one. It makes mainaining them easier and you won't promote the opportunity for one to conflict with the other. This can happen when different areas have ownership over different policies that touch the same topic.
First published on BankersOnline.com 5/10/10
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