Overdraft Payment Programs (“ ”)

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V. Lending Overdraft Payment Programs FDIC Consumer Compliance examination Manual September 2015 V Overdraft Payment Programs Introduction Prior to the 1990s, Overdraft Programs were not common among financial institutions. Since that time, however, institutions have added and/or expanded the types of Overdraft Payment Programs provided to customers. Some of these Programs impose substantial fees and interest and rely on third-party vendors to develop systems to maximize the amount of fee income generated. Customer complaints have increased, along with reported legal and enforcement actions.

Examination Approach and Applicable Laws and Regulations The FDIC’s risk-scoping examination approach requires compliance examiners to focus their attention to operational areas that present the greatest potential risk of consumer harm, as appropriate, including consideration of overdraft programs.

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