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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 any Deceptive or Abusive Acts or Practices (UDAAP) violations.
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.