It’s no secret that overdrafts have been a hot button issue in the industry and a primary area of focus for regulators. In recent years the industry has seen a flurry of new guidance, from the OCC, FDIC and CFPB, complete with new expectations for banks to consider when managing their overdraft programs. With the CFPB recently including overdrafts as one of it’s “policy priorities over the next two years”, it is clear that more changes will come and banks will be expected to keep pace with the changing landscape and modify their programs and management systems accordingly.
The best way to manage change is to have a thorough risk assessment of your overdraft program that sufficiently identifies and quantifies the various risks associated with the program and evaluates the controls in place to mitigate them. A solid risk assessment is the best way to drive the necessary changes in your institution to accommodate the evolving expectations and an excellent way to demonstrate to your regulators that you have been managing the risks particular to your program in accordance with the available guidance.
Whether you are in the process of updating your current risk assessment to accommodate all of the changes or if you are developing a risk assessment for your program for the first time, it is important that you take into account all of the appropriate regulatory concerns and understand the current available guidance.
BCC can help you with this process. We can help you catch up on rule-making developments, discuss best practices we have seen in the industry, and help you make the necessary changes at your institution to keep up with the regulatory expectations. With an organized and knowledgeable approach you will be better prepared to demonstrate that you have appropriately managed your program during your next examination!