Transcription of Overdraft Payment Programs (“ ”)
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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.
frequent users of fee- based overdraft products to opt-in to these programs while obscuring the availability of alternatives. Targeting customers who may be least able to afford such products can raise safety-and-soundness concerns about potentially unsustainable customer debt. …
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