800-809-2307
Four Letters. Infinite Potential.

Does your overdraft program pass the UDAAP test?


 

If your bank or credit union is running a “Do-It-Yourself” overdraft program,

here are 5 questions you should ask in order to determine if you’re at risk for a Unfair or Deceptive or Abusive Acts or Practices (UDAAP) violation.

UDAAP are misleading or harmful behaviors by those who offer financial products or services to consumers, and are illegal as defined by the Dodd-Frank Act of 2010. These can be advertising materials or actions intended to deceive consumers or harm them financially.

1. Do you provide a full program description, including charges, features and restrictions? 

2. Are advertisements related to your program misleading? Do they leave important information out (fees charged, or lead the consumer to think the service is free)?

3. Do your disclosures include information on the cost and consequences of overdrafts?

4. Do your account holders receive any warning or notice that an overdraft might occur?

5. Do your account holders have the opportunity to “opt-in” to have overdraft protection for everyday ACH and point of sale transactions?

Compliance continues to be a top concern for many.  Overall these are a few very important questions you should consider when evaluating your overdraft program.

 



Watch these videos to learn more about the benefits of a fully-disclosed overdraft program and our compliance approach.

 

2020 40 years Academy account holder account holder retention account holder strategies account holder strategies; growth strategies; account holders Advice Agreement analysis Analytics announcement Assistance ATMs Attendees attracting talent Automation B2B Balance Bank Bank of Pacific Banking banking services banks banks and credit unions batching Benefit best practices board governance board member board of directors bottom line branch equipment branch profitability branding Bryan Hanks budget bundling business business culture business environment business practices business processes business strategies career advice case studies Case Study CEO onboarding CFPB change Charles Shanley Cher Cheryl Lawson Choose Chris Karstens Classroom clients Cloud Cohron commitment Communication communications Competitive Complaint Compliance compliance examinations compliance risks compliant Consistency Consistent consultant consulting Consumer Consumer FInancial Protection Bureau consumer protection Consumers Contingency Contract Contract Analysis Contract Negotiation contract negotiations Contract Optimizer Contract Renegotiations contract review contract staffing Contracts Convenience core processor contracts Cornerstone Credit Union League corporate culture corporate governance CPE credits credit card contracts credit cards Credit Union credit unions Crissandra Fry CSS culture customer service cyber security Damian Darin Byrd Data database Deal debit card contracts Debt Decisions Dick Miller digital directors Disclosed discounts Discussion Dynamic economy Education efficiency studies election Emergency employee employee retention employees EMV migration evaluation Evolve executive search Expectations Expense expense management expense reduction expense studies expenses Experience Expert expert negotiations Experts Facilitators FastTrack Federal Reserve Board Feedback fees Financial Financial Institution financial institutions financial services financial stability FinTech Floyd's Forum Free Analysis full disclosure Fully Generating Income generating leads generation governance government Halloween Hammond hiring HKW Holiday Holidays HR HR Consulting HR policies Hubur human capital human resources Implementation improved efficiencies improved results Inc. income income enhancement Innovate Innovative interview strategies interview tips IT contracts Jai James Jan Southern Jennifer Peoples Jim Griffis JMFA JMFA Academy JMFA clients JMFA News JMFA Next Generation Overdraft Privilege job search John M. Floyd John M. Floyd & Associates Keith Hughey Kelly Flynn Kennedy Kim Kreps Lawyer