Overdraft Payment Programs (“ ”)
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. In many cases, fees are repeatedly charged and are often disproportionate to the amount originally intended to be funded. Some institutions manipulate their transaction processing order to maximize fee income.
• The Truth in Savings Act (TISA) and Regulation DD; • The Electronic Fund Transfer Act (EFTA) and Regulation E; • Section 5 of the Federal Trade Commission Act (FTC Act) governing Unfair or Deceptive Acts or Practices (UDAPs); • The Equal Credit Opportunity Act (ECOA) and Regulation B;
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