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DOES YOUR OVERDRAFT PROGRAM PASS THE UDAAP TEST?

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If your bank or credit union is running a u201cDo-It-Yourselfu201d overdraft program,nnu003cstrongu003ehere are 5 questions you should ask in order to determine if youu2019re at risku00a0u003c/strongu003efor a Unfair or Deceptive or Abusive Acts or Practices (UDAAP) violation.nnu003cstrongu003eUDAAP are misleading or harmful behaviors by those who offer financial products or services to consumersu003c/strongu003e, 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.nn1. Do you provide a full program description, including charges, features and restrictions?nn2. 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)?nn3. Do your disclosures include information on the cost and consequences of overdrafts?nn4. Do your account holders receive any warning or notice that an overdraft might occur?nn5. Do your account holders have the opportunity to u201copt-inu201d to have overdraft protection for everyday ACH and point of sale transactions?nnCompliance continues to be a top concern for many.u00a0 Overall these are a few very important questions you shouldu00a0u003ca href=u0022https://www.jmfa.com/Tools/Overdraft-Privilege-Analysis-Requestu0022u003econsider when evaluating your overdraft programu003c/au003e.

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