April 20, 2020
As consumers start to receive stimulus payments there is no specific provision in the CARES Act for collecting on negative balances or accounts previously charged off due to a negative balance. This episode features a discussion of the potential reputational risks and compliance concerns.
JMFA EVP-Compliance Review Cheryl Lawson and Morrison & Foerster Partner Obrea Poindexter share their insights on what banks and credit unions should consider when making the decision as to how to handle receipt of deposits to accounts that are overdrawn or in collections. Together, they also weigh in on some of the action items you can take to positively impact account holder relationships during this unprecedented crisis.
1:23 – Overview of CARES Act
3:20 – Strategic opportunities for communicating with account holders
6:01 – Potential examiner issues and reputational risks
8:29 – Documenting adjustments of policies
11:24 – How financial institutions across the nation are handling things
13:49 – Examples of actions JMFA clients are taking
16:03 – What to keep in mind for account holders
18:23 – Balancing needs for both account holders and your financial institution