What’s the big deal with using the available balance vs. the ledger balance when it comes to overdrafts? Well, the big deal is Section 5 of the Federal Trade Commission Act, which addresses unfair or deceptive acts or practices. It’s safe to say most financial institutions are going to want to steer clear of “unfair and deceptive” at all costs.
The regulatory agencies have been bringing this to our attention over the last four or five years. It started with the CFPB back in 2015, then the regulatory agencies collectively through the Outlook Live webinar series in November 2016, and most recently the Federal Reserve addressed it through their consumer compliance supervisory bulletin in July 2018.
Check out the video as Jerod gives more details.
This is the kind of thing we will cover during our “Overdraft Requirements & Best Practices” webinar on June 20, 2019. We’re going to spend two hours talking overdrafts, for example, hot spot areas, best practices, regulator expectations, etc. You don’t want to miss this!
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